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The reporting thresholds for H2S are 25,000 pounds manufactured or processed or 10,000 pounds otherwise used. Reporting is required if a facility meets either of these thresholds, is in a specific industrial sector (e.g., manufacturing, mining, electric power generation), and employs 10 or more full-time equivalent employees.
The EPA has developed online tools to help owners and operators determine if they are subject to TRI reporting and make their submissions online. Paper submissions may also be made, but the Agency has a strong preference to keep the entire process electronic. More information on the mechanics of reporting is here.
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H2S uses
H2S is a colorless, flammable, extremely hazardous gas with a rotten egg smell. Common names for the gas include sewer gas, stink damp, swamp gas, and manure gas. It occurs naturally in crude petroleum, natural gas, and hot springs. In addition, H2S is produced by bacterial breakdown of organic materials and human and animal wastes (e.g., sewage). Industrial activities that can produce the gas include petroleum/natural gas drilling and refining and processes associated with wastewater treatment, coke ovens, tanneries, and kraft paper mills. H2S can also exist as a liquid compressed gas.
H2S has few important commercial uses. However, it is used to produce sulfur, one of the most commercially important elements. About 25 percent of all sulfur is obtained from natural gas and crude oil by conversion of one-third of the H2S to sulfur dioxide.
TRI history
H2S was added to the TRI list of chemicals in a final rule published December 1, 1993. About 8 months later, the EPA issued an administrative stay of the TRI requirement for H2S to review issues stakeholders brought to the Agency’s attention after promulgation. Specifically, in its proposed rule, the EPA cited chronic respiratory effects as the “chronic human health effects” criterion for the listing; but in the final rule, the Agency switched that criterion to chronic neurotoxic effects. In other words, the public had no opportunity to comment on the actual human health effect the EPA used to support the listing. The EPA viewed this as a valid objection to the final rule.
Members of the regulated community also said that the EPA diverged from past listing practice by not including an exposure analysis in the decision to list H2S (i.e., the listing was based on the toxicity of the substance rather than the risk of people being exposed to it).
While not agreeing that the exposure analysis decision was inconsistent with past practice, the Agency saw enough merit in the two objections to issue the administrative stay on the rule that required H2S reporting under the TRI. The stay only suspended the effectiveness of the listing rule; the rule was not withdrawn and was reactivated as it was originally written.
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Chronic health effects
In lifting the stay, the EPA reiterates that its technical evaluation shows that H2S can reasonably be anticipated to cause chronic health effects in humans. The Agency states that chronic health effects have been observed in laboratory animals exposed to low levels of H2S. In addition, the EPA states that the technical evaluation shows that the toxicity of H2S can reasonably be anticipated to cause significant adverse effects in aquatic organisms. “As an aside,” stated the Agency when lifting the stay, “EPA notes also that it believes that the above findings clearly demonstrate the correctness of the Agency’s final decision in December 1993 to list hydrogen sulfide on the EPCRA section 313 toxic chemicals list based on the listing criteria in EPCRA sections 313(d)(2)(B) and (C).
“By lifting the stay, communities will have more information about this toxic chemical,” the Agency adds.