2016EPCRA Report(Period Jan-Dec2016) Combined Appendices.pdf

NAVAL STATION GREAT LAKES, IL

EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT

(EPCRA)

CALENDAR YEAR 2016

COMPLIANCE REPORT, SECTIONS 302, 311/312, AND 313

PREPARED FOR:

NAVAL FACILITIES ENGINEERING COMMAND MID-ATLANTIC

9324 VIRGINIA AVENUE

BLDG. Z-144

NORFOLK, VA 23511

BASE CONTRACT NUMBER N40085-15-D-8752

TASK ORDER NUMBER 0005

PREPARED BY:

HGS ENGINEERING, INC.

1121 NOBLE STREET

ANNISTON, AL 36201

21 APRIL 2017

EPCRA Section 302, 311/312, 313 March 2017 Naval Station Great Lakes & Fort Sheridan Table of Contents

Table of Contents

Table of Contents

List of Appendices

Acronyms and Abbreviations

Executive Summary

1.0 Introduction

2.0 Background

2.1 EPCRA Section 302 – Emergency Planning Notification

2.2 EPCRA Section 311 and 312 – Safety Data Sheet Reporting and Hazardous Chemical Inventory Reporting

2.3 EPCRA Section 313 – Toxic Release Inventory Reporting

3.0 Overview of Procedures and Primary Data Sources

4.0 Chemical Inventory Data for NSGL

4.1 ERP Chemical Inventory Data

4.2 Bulk Petroleum, Oil, and Lubricant (POL) Storage

4.3 Fire Suppression Chemical Data

4.4 Compressed Gas Inventory

4.5 Lead-Acid Batteries

4.6 Miscellaneous Hazardous Material Inventory

5.0 Discussions of Exemptions, EPCRA Section 312

5.1 Consumer-Equivalent/Personal Use Items

5.2 Solid Manufactured Items

5.3 Research Laboratory/Medical Facility Exemption

5.4 Fuels at a Retail Gas Station

5.5 Resource Conservation and Recovery Act (RCRA)-Regulated Hazardous Wastes

6.0 EPCRA Section 302 Threshold Evaluation and Results

7.0 EPCRA Section 312 Threshold Evaluation and Results

8.0 EPCRA Section 313 Threshold Evaluation and Results

9.0 Conclusions

Naval Station Great Lakes & Fort Sheridan List of Appendices

List of Appendices

Appendix A 2016 NSGL Tier II Report

Appendix B 2016 Fort Sheridan Lift Station Tier II Report

Appendix C 2016 NSGL 302 Report

Appendix D NSGL EPCRA Reporters and Users

Appendix E 2016 Raw ERP EPCRA Data

Appendix F 2016 Section 312 Threshold Exceedance Table

Appendix G 2016 NSGL Evaluation of Preliminary List

Naval Station Great Lakes & Fort Sheridan Acronyms and Abbreviations

Acronyms and Abbreviations

CAS .............................................................................................................. Chemical Abstracts Service

CY .................................................................................................................................... Calendar Year

CHRIMP ......... Consolidated Hazardous Material Reutilization and Inventory Management Program

DoD ..................................................................................................................... Department of Defense

DPW ........................................................................................................... Department of Public Works

EHS ...................................................................................................... Extremely Hazardous Substance

EPA ............................................................................. United States Environmental Protection Agency

EPCRA ........................................................... Emergency Planning and Community Right-to-know Act

ERP .......................................................................................................... Enterprise Resource Planning

HAZMIN .......................................................................................... Hazardous Materials Minimization

HMMS ................................................................................... Hazardous Material Management System

IEMA ...................................................................................... Illinois Emergency Management Agency

LEPC .......................................................................................... Local Emergency Planning Committee

MSDS ............................................................................................................ Material Safety Data Sheet

NSGL .............................................................................................................Naval Station Great Lakes

OSHA ........................................................................... Occupational Safety and Health Administration

PBT .................................................................................................... Persistent Bioaccumulative Toxic

POL .......................................................................................................... Petroleum, Oil, and Lubricant

RCRA .................................................................................... Resource Conservation and Recovery Act

SDS .............................................................................................................................. Safety Data Sheet

SERC........................................................................................ State Emergency Response Commission

Tier II Form ............................................. Tier II Emergency and Hazardous Chemical Inventory Form

TPQ ........................................................................................................... Threshold Planning Quantity

TRI .................................................................................................................... Toxic Release Inventory

Naval Station Great Lakes & Fort Sheridan Executive Summary

Executive Summary

This compliance report documents the data, approach, rationale, and assumptions used to identify chemicals (and perform threshold evaluations) that are reportable under the Emergency Planning and Community Right-to-know Act (EPCRA) Sections 302, 311/312, and 313 at Naval Station Great Lakes (NSGL) and Fort Sheridan during calendar year (CY) 2016.

EPCRA Sections 311 and 312 include the United States Environmental Protection Agency (EPA) requirements for reporting hazardous chemical storage. Chemicals that exceed applicable reporting thresholds during a given CY must be documented on Tier II Forms that must be submitted on or before March 1 of the following CY. DoD policy requires installations, to the extent permitted by law, to comply with the provisions of EPCRA regulations.

Data on hazardous material inventory maintained by the Hazardous Materials Minimization Center was obtained from the Navy’s Enterprise Resource Planning (ERP) database. Additional data on hazardous material managed at the installation was obtained from station personnel. Department of Public Works (DPW)/Environmental personnel provided data on bulk fuels and other ODSs not tracked through the ERP database.

17 chemicals at NSGL and one chemical at Fort Sheridan exceeded Section 312 reporting thresholds based on the maximum amount of non-exempt chemicals maintained on site during CY 2016. The Tier II Emergency and Hazardous Chemical Inventory Forms (Tier II Forms) were submitted prior to 01 March 2017 as required, and are included as attachments.

No chemicals exceeded Section 313 reporting thresholds at either site for CY 2016 after exemptions and calculation-based exclusions were applied. Consequently, no Form R submittal was required.

Two chemicals exceeded Section 302 reporting threshold for extremely hazardous substances (EHSs). An EPCRA Section 302 Emergency Planning Notification Form was filed for CY 2016 to provide an online copy of the form reporting the EHSs that exceed the threshold quantities; this was a one-time submittal. The Section 302 form was submitted with the Tier II forms, and is included as an attachment.

Naval Station Great Lakes & Fort Sheridan Introduction

1.0 Introduction

This report documents the approach, rationale, and assumptions used to identify chemicals that are reportable under the Emergency Planning and Community Right-to-know Act (EPCRA) Sections 302, 311/312, and 313 at Naval Station Great Lakes (NSGL) and Fort Sheridan during calendar year (CY) 2016. Supporting documentation, including the raw EPCRA data from the ERP system, a threshold exceedance table, and an evaluation of the preliminary list are included in Appendices E, F, and G, respectively. Copies of the Emergency and Hazardous Chemical Inventory Tier II Forms (Tier II Forms) for NSGL and Fort Sheridan, as well as the 302 Report for NSGL are included in Appendices A, B, and C, respectively.

2.0 Background

The Emergency Planning and Community Right-To Know Act of 1986 (EPCRA) was implemented at the same time that the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was being reauthorized. EPCRA was enacted under Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA), and is often referred to as SARA Title III.

2.1 EPCRA Section 302 – Emergency Planning Notification

Facilities that maintain Extremely Hazardous Substances (EHS) on-site in quantities greater than corresponding threshold planning quantities as listed must cooperate in emergency plan preparation.

EPCRA 302 Reporting Requirements

If the chemical is an EHS, the reporting threshold is 500 pounds or the Threshold Planning Quantity (TPQ), whichever is less. If the chemical is an EHS, the facility is also required to file a Section 302 Notice. This notice alerts emergency planners that an EHS is present at the facility in quantities in excess of the TPQ.

The list of EHS and the TPQs can be found at 40 CFR 355 Appendix A and B, or on the EPA List of Lists.

The facility must also provide notice to the LEPC of any changes that may be relevant to emergency planning, within 30 days of the change. Changes may include:

An EHS is moved to a different location at the facility, or stored in a different manner;

An EHS is no longer present at the facility;

Notification that the facility is no longer in operation.

The Section 302 Notice must be submitted to the following:

Illinois Emergency Management Agency (IEMA) as the SERC, via electronically through Tier II Manager website, and

The appropriate LEPC, via printed hard copy from Tier II Manager website.

Naval Station Great Lakes & Fort Sheridan Background

2.2 EPCRA Section 311 and 312 – Safety Data Sheet Reporting and Hazardous Chemical Inventory Reporting

EPCRA Sections 311 and 312 include United States Environmental Protection Agency (EPA) requirements for reporting hazardous chemical storage. EPCRA Section 311 requires facilities that store hazardous material exceeding certain threshold quantities to submit copies of their Material Safety Data Sheets (MSDSs) and/or Safety Data Sheets (SDSs) or a list of the hazardous chemicals to the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC), and the local Fire Department. An SDS must be filed within 90 days of the date of a new material brought onsite. This notice is commonly known as a 311 Notice. The threshold quantities for EPCRA Section 311 compliance reporting are defined under EPCRA Section 312.

EPCRA Section 312 requires facilities to identify all hazardous material that were present on site in quantities 10,000 pounds or more at any one time during the CY. In addition, facilities are required to identify all extremely hazardous substances (EHSs) listed within EPCRA Section 312 regulations that were present on site at any one time during the CY in quantities in excess of 500 pounds or the Threshold Planning Quantity (TPQ), whichever is lower. Chemicals that exceed EPCRA Section 312 reporting thresholds during a given CY must be documented on Tier II Forms and submitted to the SERC, the LEPC, and the local Fire Department on or before 01 March of the year following the reporting calendar year period.

Tier II and SDS submissions must be made to each of the following:

IEMA as the SERC, electronically through Tier II Manager website, The appropriate LEPC, via printed hard copy from Tier II Manager website, and

The local fire department, via printed hard copy from Tier II Manager website.

The following diagram shows the general steps used in determining if NSGL must report under EPCRA Sections 302 (EHS), and/or 311/312 (HC).

Naval Station Great Lakes & Fort Sheridan Background

2.3 EPCRA Section 313 – Toxic Release Inventory Reporting

Facilities must complete and submit a toxic release inventory (TRI) form annually for certain chemicals that are manufactured, processed, or otherwise used above applicable threshold quantities.

Section 313 Reporting Requirements

If the chemical is a TRI chemical, and a threshold is exceeded, a TRI Form R must be submitted, via the TRIME web portal on the EPA TRI website by July 1 of each year. It has been previously determined that NSGL does not manufacture or process TRI chemicals, but only otherwise uses them.

The otherwise use threshold is 10,000 pounds annually for most chemicals, and much lower for persistent bioaccumulative toxic (PBT) chemicals (see the TRI web page or EPA List of Lists for TRI chemicals and thresholds).

The basic steps to EPCRA 313 reporting are as follows:

a. Compile chemical usage data from the EPCRA Data Management Tool reports and other records (NSGL EPCRA Reporters or EPCRA Chemical Users).

b. Complete quality assurance of chemical data.

c. Consolidate members of reportable chemical categories under EPCRA Section 313.

d. Identify chemicals that are subject to reporting under EPCRA Section 313.

e. Identify PBT chemicals and respective PBT reporting thresholds.

f. Re-evaluate EPCRA Section 313 exemptions to determine if they apply.

g. Complete EPCRA Section 313 otherwise used threshold evaluation.

h. Calculate release and offsite transfer quantities for chemicals exceeding an EPCRA

i. Section 313 reporting threshold.

j. Complete Form Rs for chemicals exceeding an EPCRA Section 313 reporting threshold.

The following diagram shows the general steps used in determining if NSGL must report under EPCRA Section 313 (TRI).

Naval Station Great Lakes & Fort Sheridan Overview of Procedures and Primary Data Sources

3.0 Overview of Procedures and Primary Data Sources

A site visit to support EPCRA Section 311/312 reporting was conducted during the week of 05 December 2016. During the site visit, a plan of action was discussed to complete the necessary data collection and key facility personnel were interviewed including personnel from Environmental, the Hazardous Materials Minimization (HAZMIN) Center, DPW, and other tenants. Subsequently, follow-up data was provided by tenant personnel via email.

Data is gathered through three primary sources: The ERP System, EPCRA Reporters, and EPCRA Users. EPCRA Reporters consists of departments and tenants responsible for products/chemicals that are currently reported to state or federal regulatory agencies under EPCRA. EPCRA Users are departments and tenants responsible for products/chemicals that contain hazardous chemicals. The ERP contains the majority of hazardous material inventory at NSGL, but not all. Some Departments and tenants obtain materials through other means and the data is therefore not in the ERP, requiring information collection from EPCRA Reporters and EPCRA Users. A listing of current EPCRA Reporters and EPCRA Users is located in Appendix D.

The primary sources of hazardous material and chemical inventory data include the following:

The HAZMIN Center is responsible for supplying the majority of hazardous material to the Navy and some tenant activities at NSGL. HAZMIN Center personnel track hazardous material purchases though the Navy’s ERP database including hazardous material container issues and returns, current hazardous material inventory, and chemical composition data for each material. An initial download of data from the ERP database for CY 2016 was obtained from HAZMIN Center personnel during November 2016. Following discussions with the ERP database administrator during the site visit, a second download of ERP data was obtained on 11 January 2017. The ERP data was reviewed and vetted with EPCRA Users and Reporters because the chemicals may be in products that are exempt, and/or the quantities of hazardous chemicals in the output are inaccurate. The data in the ERP System EPCRA Report output is not always accurate due to both ERP system errors and data management issues.

The HAZMIN Center does not track hazardous material used by all departments and tenants. This includes bulk fuels, compressed gases, ODSs, and lead-acid batteries. In addition, hazardous material stored in bulk vats and other process equipment in shops is not tracked through the ERP system. Inventory data for these materials were obtained from the organizations responsible for maintaining and/or tracking these materials.

MSDSs and/or SDSs were obtained from organizations and personnel responsible for maintaining the hazardous material, and from publicly available sources.

Where product MSDSs and/or SDSs were available, chemical constituents of each hazardous material were identified using the Chemical Abstracts Service (CAS) Number. Quantities of each chemical, as contributed by various hazardous materials, were then summed to determine the total amount of each chemical stored on site. Where individual chemical constituents of hazardous material could not be

Naval Station Great Lakes & Fort Sheridan Chemical Inventory Data for NSGL identified, the hazardous material was reported as a mixture and quantities of that hazardous material were summed from all available sources. The total for each chemical or hazardous material was then compared to applicable EPCRA Section 312 reporting thresholds. Section 4.0 discusses threshold evaluations in greater detail. Exemptions were evaluated for chemicals and hazardous material that approached or exceeded reporting thresholds, and were applied as appropriate. Section 5.0 describes the exemptions that were applied.

4.0 Chemical Inventory Data for NSGL

As discussed in Section 2.0, hazardous material inventory data from a variety of sources were used to conduct threshold evaluations for determining EPCRA Section 312 reporting eligibility at NSGL. The various sources of hazardous material data are discussed in detail below, along with a summary of threshold quantities contributed by each source.

4.1 ERP Chemical Inventory Data

The HAZMIN Center is responsible for receiving, storing, distributing, and tracking the bulk of hazardous material, and is the principle organization responsible for implementing the Navy’s Consolidated Hazardous Material Reutilization and Inventory Management Program (CHRIMP) at

NSGL.

All hazardous material transactions between the HAZMIN Center and organizations on the installation are tracked through the ERP system. Transactions are performed on a container basis. Data tables within the ERP system are populated with information on each hazardous material including container size, material specific gravity, and chemical composition. Container transactions can be converted into mass and chemical mass transactions and provide a means to calculate individual chemical usage by organization. ERP inventory functions allow calculation of chemical quantities by location.

The ERP EPCRA Report Screen was used to determine hazardous materials present on site and the storage location for each hazardous material at NSGL during CY 2016.

4.2 Bulk Petroleum, Oil, and Lubricant (POL) Storage

POLs are stored in various locations throughout NSGL in bulk storage tanks. These include diesel fuel, gasoline, E-85, biodiesel, and new/used lube oil. These materials are not tracked in the ERP system. A storage tank inventory was obtained from the NSGL Environmental Department to calculate the stored amounts of these materials. It was conservatively assumed that the maximum amount of hazardous material on site at any time during CY 2016 was equal to the maximum storage capacity for that product.

4.3 Fire Suppression Chemical Data

Information was provided by the Fire Department and Navy Training Department regarding the storage of ABC dry chemical and carbon dioxide fire suppression chemicals at NSGL during CY 2016.

Weights of the chemical constituents of firefighting materials were calculated based on available MSDSs and/or SDSs and added to the weights from other sources.

Naval Station Great Lakes & Fort Sheridan Discussions of Exemptions, EPCRA Section 312

4.4 Compressed Gas Inventory

Compressed gases are stored at various locations at NSGL. NSGL personnel provided an estimate of the amounts of various compressed gases stored on site during CY 2016. These included propane, argon, and acetylene. Weights of each compressed gas were added to the weights from other sources.

4.5 Lead-Acid Batteries

Non-exempt lead-acid batteries are present in multiple locations across the installation. These include batteries used in computer battery backup systems and forklifts. The weights of each battery, and the percentage by weight of lead and sulfuric acid within each battery were determined from MSDSs and/or SDSs provided by the manufacturer. These weights were added to weights calculated from other sources.

4.6 Miscellaneous Hazardous Material Inventory

Alum, chlorine, and other chemicals are used at the NSGL water treatment plant and are stored in liquid solution in storage tanks. In addition, several other chemicals are used throughout the installation.

5.0 Discussions of Exemptions, EPCRA Section 312

Various exemptions are available to facilities under EPCRA Section 312 to reduce the burden of compliance with reporting requirements. Chemicals associated with exempt uses are not required to be included in EPCRA Section 312 threshold evaluations or Tier II reporting. Some of the available exemptions, including those related to fertilizer held for sale by a retailer, chemicals used in routine agricultural operations, and products regulated by the Food and Drug Administration, are not applicable to NSGL or do not significantly impact threshold calculations; thus, these exemptions are not discussed further. Exemptions that significantly impacted the threshold evaluations and EPCRA Section 312 reporting requirements for NSGL are summarized below.

5.1 Consumer-Equivalent/Personal Use Items

Substances that are present in the same form and concentration as products packaged for distribution and use by the general public are not required to be considered in the EPCRA Section 312 threshold determinations or Tier II reporting. This exemption was applied to a variety of materials including consumer-equivalent batteries, paints, lubricants, coolants, insecticides, small ABC-type fire extinguishers (less than 10-pounds charge), and cleaning compounds as well as products meant for personal use (e.g., hand sanitizers). Large lead-acid batteries, as well as banks of lead-acid batteries connected in series, do not qualify for this exemption; therefore, batteries in power backup systems and large batteries in forklifts were not exempted from threshold calculations. In addition, motor oils and hydraulic fluids packaged in 55-gallon drums were not considered to qualify for this exemption.

5.2 Solid Manufactured Items

Substances present as a solid in any manufactured item, such that exposure to the substance does not occur under normal conditions of use, are not required to be considered in the EPCRA Section 312

Naval Station Great Lakes & Fort Sheridan Discussions of Exemptions, EPCRA Section 312 threshold determinations or Tier II reporting. Per Department of Defense (DoD) policy, small arms ammunition and other munitions end items were considered to be solid manufactured items and were exempted. Sealed dry chemistry batteries used in communications equipment also qualify for this exemption and were excluded from threshold calculations. Lead-acid batteries including sealed valve-regulated and gel type batteries were not considered to qualify for this exemption.

5.3 Research Laboratory/Medical Facility Exemption

Chemicals used in a research laboratory or other medical facility under the direct supervision of a technically qualified individual are not required to be considered in the EPCRA Section 312 reporting requirements. As a result of this exemption, certain hazardous chemicals stored at the dental clinic were excluded from threshold calculations. For example, compressed gases used for medical purposes would be exempt. Mercury-based amalgams would also be exempt.

5.4 Fuels at a Retail Gas Station

Retail gas stations, which sell fuel to privately-owned vehicles, are exempt from EPCRA Section 312 reporting requirements if the following conditions are met:

Less than 75,000 gallons of gasoline (all grades combined) are stored;

Less than 100,000 gallons of diesel (all grades combined) are stored;

Fuel storage is entirely underground; and

The facility is in full compliance with underground storage tank regulations.

Per Navy EPCRA guidance, Navy Exchange gas stations qualified for this exemption since they provide fuel to privately-owned vehicles. Fueling points that service only government vehicles do not qualify for the exemption.

5.5 Resource Conservation and Recovery Act (RCRA)-Regulated

Hazardous Wastes

Hazardous wastes regulated under RCRA are exempt from OSHA’s Hazard Communication Standards and, thus, do not have to be reported under EPCRA Section 312. Hazardous wastes stored on site at satellite accumulation points and 90-day storage sites were exempted from reporting. Note that used oil that is intended to be recycled is excluded from the definition of hazardous waste; therefore, this exemption was not applied to used oil.

Naval Station Great Lakes & Fort Sheridan EPCRA Section 302 Threshold Evaluation and Results

6.0 EPCRA Section 302 Threshold Evaluation and Results

A threshold evaluation summary was compiled based on material and chemical inventory data. The data were summed by CAS number, where possible, for each hazardous chemical stored at NSGL during CY 2016. Total inventory quantities for each chemical were compared to the 500-pound or lower TPQ threshold for EHSs, as applicable.

The following chemical(s) exceeded reporting thresholds at NSGL in CY 2016:

No chemicals exceeded reporting thresholds at Fort Sheridan in CY 2016.

Chemical or Product Name

CAS

Number

Total Weight

(pounds)

Thresholds (pounds)

Sulfuric Acid (non-aerosol, batteries) 7664-93-9 80,577 500 (EHS) Chlorine 7782-50-5 3,000 100 (EHS)

Naval Station Great Lakes & Fort Sheridan EPCRA Section 312 Threshold Evaluation and Results

7.0 EPCRA Section 312 Threshold Evaluation and Results

A threshold evaluation summary was compiled based on material and chemical inventory data. The data were summed by CAS number, where possible, for each hazardous chemical stored at NSGL during CY 2016. Total inventory quantities for each chemical were compared to the 10,000-pound hazardous chemical threshold and to the 500-pound or lower TPQ threshold for EHSs, as applicable.

The following chemical(s) exceeded reporting thresholds at NSGL in CY 2016:

The following chemical(s) exceeded reporting thresholds at Fort Sheridan in CY 2016:

A total of 17 chemicals were reportable for CY 2016. The following chemicals were reported in CY 2016, but not in CY 2015: Calsoft L-40 (surfactant), Sand, and Sodium Chloride (salt).

Chemical or Product Name

CAS

Number

Total Weight

(pounds)

Thresholds (pounds)

Argon 7440-37-1 23,258 10,000 Bio-Diesel N/A 73,392 10,000 Bioxide (Ammonium Calcium Nitrate Solution) N/A 109,125 10,000 Calsoft L-40 N/A 55,200 10,000 Carbon Dioxide 124-38-9 49,386 10,000 Chlorine 7782-50-5 3,000 100 (EHS) Diesel Fuel #2 68476-34-6 130,684 10,000 E-85 Ethanol Fuel N/A 62,550 10,000 Klaraid PC1192P (Water Treatment Polymer Solution) N/A 17,180 10,000 Liquid Alum (Aluminum Sulfate Aqueous Solution) 10043-01-3 22080 10,000 Lubricating Oil (new and used) 103,199 10,000 Propane 74-98-6 181,440 10,000 Sand 14808-60-7 200,000 10,000 Sodium Chloride (salt) 7647-14-5 4,000,000 10,000 Sulfuric Acid (non-aerosol, batteries) 7664-93-9 80,577 500 (EHS) Unleaded Gasoline 470,862 10,000

VX456 (CHLORITE SOLUTION WITH SODIUM NITRATE) 32,483 10,000

Chemical or Product Name CAS Number Total Weight

(pounds) Thresholds (pounds)

Bioxide (Ammonium Calcium Nitrate Solution) N/A 29816 10,000

Naval Station Great Lakes & Fort Sheridan EPCRA Section 313 Threshold Evaluation and Results

8.0 EPCRA Section 313 Threshold Evaluation and Results

A threshold evaluation summary was compiled based on material and chemical inventory data. The data were summed by CAS number, where possible, for each hazardous chemical stored at NSGL during CY 2016. Total inventory quantities for each chemical were compared to the 25,000-pound threshold for manufacturing and processing, 10,000-pound threshold for otherwise used, or lower TPQ threshold for PBTs, as applicable. Some exemptions and exclusions were met as described below.

Exemptions and Exclusions Pertaining to Section 313

Chlorine [Exemption] Chemicals for personal use:

The chlorine is added to the water supply system to prepare potable water for consumption at the facility.

Unleaded Gasoline - Toluene, Xylene, Methyl Tertiary Butyl Ether, 1,2,4-Trimethylbenzene, Cumene, Ethylbenzene, Benzene, n-Hexane, Cyclohexane

[Exemption] Chemicals used to maintain facility motor vehicles: The chemicals in the gasoline are used to fuel DoD installation motor vehicles.

Lubricating Oil (New and Used) – Zinc and Zinc Compounds (2%)

[Exclusion] Calculations showed approximately 2,000 lbs of zinc and zinc compounds which is below the 10,000 lb threshold.

Sulfuric Acid (Battery Acid) [Exemption] Article: Batteries are a manufactured item with a specific design which does not release chemicals during normal conditions of use.

Certain glycol ethers category (ethylene glycol)

[Exclusion] Calculations showed approximately 2,091 pounds of ethylene glycol is otherwise used each year which is below the 10,000 lb threshold

Nitric Acid [Exclusion] Calculations showed approximately 1,706 pounds of nitric acid is otherwise used each year which is below the 10,000 lb threshold

HCFC-22, HCFC-123 [Exclusion] DPW reported less than 200 pounds/year of HCFC-22 and HCFC -123 is otherwise used per year in recharging systems.

For each substance in the inventory report that could exceed thresholds the CAS number of the substance was compared to the TRI list. In some cases multiple CAS numbers were identified from the SDS and their potential maximum percentage of the mixture was used to compare with the TRI list and

Naval Station Great Lakes & Fort Sheridan EPCRA Section 313 Threshold Evaluation and Results reporting thresholds. Some materials were eliminated from consideration because their SDS clearly stated that the material contains no chemicals that are regulated by Section 313. No chemicals were identified as meeting the de minimis exemption.

After all calculations and exemptions were applied, it was determined that no chemicals at NSGL or Fort Sheridan which were manufactured, processed, or otherwise used during CY 2016 require Form R reporting.

Naval Station Great Lakes & Fort Sheridan Conclusions

9.0 Conclusions

Based on the information obtained from the chemical inventory, the maximum quantities of the following chemicals and hazardous materials exceeded their respective EPCRA reporting thresholds for CY 2016:

EPCRA Section 302 at NSGL:

Chlorine Sulfuric Acid (Battery Acid)

EPCRA Section 302 at Fort Sheridan:

None

EPCRA Section 312 at NSGL:

Argon Bioxide (Ammonium Calcium Nitrate Solution) Carbon Dioxide E85 Ethanol Fuel Liquid Alum (Aluminum Sulfate Aqueous Solution) Propane Sodium Chloride (Salt) Unleaded Gasoline Bio-Diesel Calsoft L-40 Chlorine Diesel Fuel #2 Klaraid PC1192P (Water Treatment Polymer Solution) Lubricating Oil (new and used) Sand Sulfuric Acid (Battery Acid) VX456 (Chlorite Solution with Sodium Nitrate)

EPCRA Section 312 at Fort Sheridan:

Bioxide (Ammonium Calcium Nitrate Solution)

EPCRA Section 313 at NSGL:

None

EPCRA Section 313 at Fort Sheridan:

None