Question # 188

188. Are diesel, gasoline, and fuel oils reportable under EPCRA section 313?
Although diesel, gasoline, and fuel oils are not listed as TRI toxic chemicals, these products contain listed toxic chemicals that may be reportable under EPCRA section 313, if applicable activity thresholds are met. An EPCRA section 313 listed toxic chemical that is a constituent of a fuel that is combusted on-site is being “otherwise used” (62 FR 23834, 23851; May 1, 1997). In addition, the combustion of fuels can cause listed toxic chemicals to be generated, or “manufactured.” Toxic chemicals in fuel that are prepared for distribution in commerce are “processed.” For example, toxic chemicals in fuel contained in automobiles that are sold by a facility are considered toward the processing threshold. Estimated concentrations of toxic chemical constituents in crude oil and various petroleum products can be found in Table 3-4 of the Electricity Generating Facilities EPCRA section 313 Industry Guidance (EPA 745-B-00-004), in Table 2-2 of the Guidance for Reporting Toxic Chemicals: Polycyclic Aromatic Compounds Category (EPA 745-B-19-019), and in Table 4-8 of the Guidance for Reporting Releases and Other Waste Management Quantities of Toxic Chemicals: Lead and Lead Compounds. Estimated quantities of certain toxic chemicals manufactured as a result of fuel combustion are provided in Tables 3-8, 3-9, and 3-11 in the Electricity Generating Facilities Guidance and in Table 2-3 of the Polycyclic Aromatic Compounds Guidance. Additional toxic chemical emissions estimates from fuel combustion are provided in the Compilation of Air Pollutant Emissions Factors (AP 42) and other resources available through EPAs Clearing House for Inventories and Emissions Factors.