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Spring 2002


Articles

  • Charles City Area Chosen for Pilot Community-wide Program
  • EPA Has Lowered TRI Reporting Threshold Levels for Lead-Do You Need to Report?
  • Iowa Waste Exchange News

Charles City Area Chosen for Pilot Community-wide Program

By Chad Gookin, Public Relations Specialist

In an effort to help small business and industry in the Charles City area, the Charles City Area Development Corporation partnered with the Iowa Waste Reduction Center (IWRC) and the Institute for Decision Making at the University of Northern Iowa to implement a community-wide pilot program providing environmental compliance assistance to all qualifying area businesses. The program is scheduled for April 15-19.

The services provided by the IWRC are free and confidential to businesses with fewer than 200 employees. IWRC will do on-site visits at each requesting business to identify trouble spots in waste disposal, opportunities for pollution prevention and to answer questions about environmental regulations.

The on-site review, IWRC's primary service, consists of a waste reduction professional gathering operational information at the facility and, specifically, the management procedures associated with waste materials. Then a facility tour is conducted and additional information is gathered. After the completion of the site visit, the IWRC staff member prepares a report within four weeks, reviewing the relevant regulations and identifying pollution prevention opportunities. Six months following the report, a phone call is made to the client to follow-up on the report and see if additional information or assistance is needed.

The greater Charles City area was chosen for this pilot program because of the diversity of local business operations. By conducting visits throughout the entire community, IWRC can offer collective as well as individual business solutions to environmental and waste compliance issues.

For more information about this community-wide program or how to participate, please contact Charles City Area Development Corporation's Timothy Fox at (641) 228-3020 or the IWRC at 1-800-422-3109

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EPA Has Lowered TRI Reporting Threshold Levels for Lead- Do You Need to Report?

Lead and lead compounds have been added to the list of persistent bioaccumulative toxic (PBT) chemicals that must be reported on the Toxic Release Inventory (TRI) Form R each July 1. PBT chemicals have much lower reporting thresholds than other EPCRA Section 313 chemicals. For both lead and lead compounds, a threshold of 100 pounds per year has been established.

Before worrying about thresholds, stop and make sure you are a subject facility. Subject facilities are those that meet all three of the following criteria:

  1. Have an operation that is defined by a specified standard industrial classification (SIC) code.
  2. Employ ten full-time employees (or the equivalent of 20,000 employee-hours per year)
  3. Manufacture, process and otherwise use an EPCRA 313 chemical in excess of established threshold. Thresholds are applied individually to the activities of manufacture, process and otherwise use. Annual activity thresholds for EPCRA 313 Chemicals are:
  1. 25,000 pounds for manufacturing or processing;
  2. 10,000 pounds for otherwise use; and
  3. Chemical specific for PBTs.

SIC Code Industry 10 (except SIC codes 1011, 1081, & 1094) Metal Mining 12 (except SIC code 1241) Coal Mining 20 through 39 Manufacturing Industries 4911, 4931, OR 4939 (each limited to facilities that combust coal and/or oil for the purpose of generating power for distribution in commerce) Electric Utilities 4953 (limited to facilities regulated under the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. section 6921 et.seq.) Commercial Hazardous Waste Treatment 5169 Chemicals and Allied Products- Wholesale 5171 Petroleum Bulk Terminals and Plants 7389 (limited to facilities primarily engaged in solvent recovery services on a contract or fee basis) Solvent Recovery Services

If your facility meets both the first and second criteria, and you use lead in your operation, it is time to review the threshold values for lead. Lead and lead compounds are listed separately and threshold determinations should be made for each if applicable. The EPA excludes lead present in stainless steel, brass and bronze from PBT threshold determinations. The EPCRA 313 Chemicals, including lead, present in stainless steel, brass or bronze alloys are still subject to reporting if they exceed the activity thresholds of 25,000 for manufacturing and processing or 10,000 for otherwise use.

If this is the first time you are reviewing this regulation and it applies to your operation, several resources are available to you. The IWRC can provide confidential site-specific assistance and is free to small businesses in Iowa. Contact the IWRC by phone( 319) 273-8905 with questions. The EPA's website, www.epa.gov/tri, has many useful guidance documents as well as software that can assist in preparing the TRI Form R. The EPA is sponsoring workshops to assist in TRI reporting. To learn more about the workshop or register call (913) 551-7680 or visit the web site at www.mckinzieconstruction.com Reservations are necessary.

PBT Threshold Other EPCRA 313 Chemicals Toxic Chemical Manufacture Threshold Process Threshold Otherwise Use Threshold Manufacture Threshold Process Threshold Otherwise Use Threshold Lead 100 100 100 25,000 25,000 10,000 Lead Compounds 100 100 100 100 100 100

For those familiar with TRI reporting, classifying lead as a PBT impacts other reporting requirements. They include:

  • For PBT chemicals, including lead and lead compounds, de minimis levels do not apply. De minimis levels for other EPCRA 313 chemicals are typically 1 percent or 0.1 percent. For lead present in stainless steel, brass and bronze alloys, the de minimis level for lead is 0.1 percent.

  • TRI reporting of PBT lead or lead compounds precludes businesses from using alternate reporting thresholds and Form A Certification Statement. PBT lead or lead compound reporting can not use range reporting of releases in Section 5 and of Part II of the Form R. Thus for lead compounds or lead not contained in stainless steel, bronze or brass alloys, facilities are required to report actual release numbers.

  • Finally, data precision is also impacted. In all TRI reporting, a facility should use the level of precision in estimating its releases and other waste management calculations that is supported by the available data. The level of precision required for PBT chemicals, including lead and lead compounds, is one-tenth (0.1) of a pound. Therefore, releases that are less than 0.5 pounds/year can not be rounded to zero but those less than 0.05 pounds/year can. For more information, please contact the IWRC at 1-800-422-3109.

Reporting Thresholds and Requirements for Lead

This flowchart does not apply to Lead Compounds, which is a seperately listed TRI chemical

Did the facility exceed the 25,000/10,000 lb. threshold, considering lead in stainless steel, brass or bronze alloy1, AND lead not in stainless steel, brass or bronze alloy? 1 The de minimis exemption may be considered for quantities of the lead in stainless steel, brass, or bronze alloy.

Did the facility exceed the 100 lb. threshold considering only lead not in stainless steel, brass or bronze alloy?

Did the facility exceed the 100 lb. threshold considering only lead not in stainless steel, brass or bronze alloy?

Must use Form R, without range reporting in Sections 5 and 6 of Part II.

Only required to report releases and transfers of lead not in stainless steel, brass or bronze alloy.

No reporting for lead required.

Must use Form R, without range reporting in Sections 5 and 6 of Part II.

Report releases and transfers from BOTH lead in stainless steel, brass or bronze alloy and lead not in stainless steel, brass or bronze alloy

May use Form A or Form R; range reporting can be used in Sections 5 and 6 of Part II.

Report releases and transfers from BOTH lead in stainless steel, brass or bronze alloy and lead not in stainless steel, brass or bronze alloy.

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Iowa Waste Exchange News

A Constructive Solution
By Julie Plummer, IWE Specialist, Area B

Julie Plummer
Julie Plummer

The Iowa Waste Exchange has recently found a successful match involving wood waste from the All American Homes of Iowa LLC facility that will divert nearly 600 tons of wood waste annually from Iowa landfills.

All American Homes of Iowa LLC builds approximately 20 modular homes per week inside their 153,000 sq. ft. state-of-the-art facility located in Dyersville, Iowa. These systems-built residential homes are constructed inside of the manufacturing facility in sections, and then transported to a job site 90-95 percent complete.

Iowa Waste Exchange Representative Julie Plummer has been working to assist All American Homes of Iowa LLC in finding suitable alternatives to landfill disposal for many of the construction materials used in modular construction.

A nearby source collects both the dimensional lumber and oriented strand board from their manufacturing facility on a weekly basis. The scrap wood is then ground into sawdust consistency, and is reused by area farmers as animal bedding. Treated wood, sometimes unsuitable for animal bedding due to the glues used in its production, is mixed together with the clean sawdust in a ratio which allows all of the wood waste to be reused.

According to All American Homes facility manufacturing manager Dave Moore, the partnership with the wood recycling facility has substantially impacted the cost of dealing with the wood waste in a positive way, and he is very pleased with the quality of service being provided. Up to 600 tons of treated wood and dimensional lumber scrap is generated at the All American Homes of Iowa LLC facility annually, and so this reuse is providing a cost savings to the manufacturer as well as saving valuable space in an Iowa landfill.

Cleanliness is Next to Profit
By Jim Reimer, IWE Specialist, Area G

Jim Reimer
Jim Reimer

IWE Resource Specialist, Area G During an on-site assessment of Heritage Lace of Pella, Jim Reimer, IWE Area Resource Specialist, was shown boxes filled with various finished lace products in storage. Dave Heinen, the operations manager for Heritage Lace, informed him it was soiled with small spots of equipment dirt and grease. They had 20,000 pounds in storage and generated about 20,000 pounds per year.

The company had taken the lace to a professional dry cleaning business. However, after cleaning the lace it looked used and could not be sold. Next, they tried to spot clean it themselves. Due to time constraints they discontinued the process. They were at a loss as what to do. They disliked the idea of having to landfill it. They contacted Reimer to see if he had any ideas.

Reimer contacted Ben and Doris Fuhs who own and operate Rainbow International a janitorial and vending business in Ottumwa. Ben said he would be happy to meet with the Heritage Lace operations manager to discuss mutual business interests.

Rainbow International took on the challenge of cleaning the lace to the satisfaction of Heritage Lace. Heritage Lace now sells the cleaned lace as a premium product for a profit. Not to mention, the $440.00 savings from disposal costs.

Boy Scouts to the Rescue
By John Koch, IWE Resource Specialist, Area F

John Koch
John Koch

Culligan Store Systems, Iowa City, Iowa, provides bottled water services to area retail outlets. Providing water dispensing equipment and water containers is also included in their service. Manager Rob Wheeler contacted IWE Area Resource Specialist John Koch about plastic waste they wanted to recycle. There was not a place to take the material in Iowa City and they did not want to send it to a landfill.

When Koch picked up samples from the company, he learned that the bulk of the material was two- and three-gallon bottles that were unusable because the containers had a store label on them that they no longer serviced. The bottles had never been used and were suitable for holding potable water.

Koch asked them to hold off recycling the bottles while he tried to find someone who could use them. He then contacted Cindi Rader at the Boy Scouts office in Cedar Rapids, and she agreed to put a bottle on display to see if any of the scout troops were interested in them for use on camping trips. A few days later, she told Koch the troops were interested in ten bottles. Soon after, she revised the number to 35. Later she requested an additional 50. In the end, the Boy Scouts accepted all the containers Culligan had (about a pickup truck full) and is interested in more whenever they are available.

So rather than being landfilled or recycled, the bottles will be used and reused for years to come.

Hog Heaven
By Jim Reimer, IWE Specialist, Area G

Jim Reimer
Jim Reimer

Alaniz and Son's, Inc., a mass mailing company located in Mount Pleasant, Iowa, generates 43 tons of nonrecyclable pressure sensitive paper each year. This material, known as peel and stick, has created a need for the company to find a landfill alternative.

Jim Reimer, Iowa Waste Exchange Area G Resource Specialist, was conducting an onsite assessment of Alaniz and Son's when he discovered the company's want of a reuse solution for the nonrecyclable material.

Derby Farms in Drakesville, Iowa requires about 20 tons of bedding material per week for its hog feed lot. To help offset costs, they use paper shredded in the same machine used for hay processing, and blow that material into the hog hoop buildings.

Reimer arranged a meeting with the two companies. Alaniz and Son's agreed to put the peel and stick paper waste in gaylords to be transported and attach a pallet to each gaylord to prevent the paper from flying out during transportation.

Through this successful match, Alaniz and Son's eliminated their disposal costs, Derby Farms reduced their operating expenses, and the hogs think they are in "Hog Heaven."

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© Copyright 2007 Iowa Waste Reduction Center
A Service of Business and Community Services at the
University of Northern Iowa
Suite 113, BCS Building
Cedar Falls, IA 50614-0185
phone: 319.273.8905
fax: 319.273.6582