Questions and Answers

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  • 1 - 14 of 14
Questions and AnswersKeyword(s)Category(hidden - contains search text)(hidden - contains search text)FedFac
Manufacture; Metal Compounds3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19181 19-181 181 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Manufacture (Manufactured; Manufacturing; Produce; Produced); Metal Compounds 181. Is the conversion from one metal compound to another metal compound within the same metal compound category considered manufacturing for purposes of threshold determinations and release, and other waste management calculations?Yes. The conversion of one metal compound to another metal compound within the same metal compound category is considered the manufacture of a metal compound, which must be considered toward threshold determinations. This is identical to how threshold calculations are derived for listed toxic chemicals in non-metal compound categories. The unique aspect for metal compounds, as compared to non-metal compounds within a listed compound category, is how amounts released and otherwise managed as waste are reported. As stated in the final rule (62 FR 23850; May 1, 1997), ‘if a metal is converted to a metal compound or if a metal compound is converted to another metal compound,..., a metal compound has been manufactured as defined under EPCRA section 313.’ However, provided that thresholds are exceeded, covered facilities are instructed to report only the amount of the parent metal contained in the metal compound for amounts released or otherwise managed as waste. If thresholds for both the elemental metal and its metal compounds have been exceeded, covered facilities have the option to submit one Form R that includes on their report the amounts of the elemental metal from the parent metal along with amounts of the metal portion from the metal compounds.</div></b><div style="visibility:hidden"></div></b>-
Compound; Compound Category; Multiple Chemical Category; Release Reporting; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19182 19-182 182 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Compound (Compounds); Compound Category (Chemical Categories; Chemical Category); Multiple Chemical Category; Release Reporting; Threshold Determination (Activity Threshold) 182. How would a compound that falls into two reporting categories be reported (e.g., PbCrO3) on the Form R?A compound that has constituents in two listed categories would have to be included under both categories when submitting a Form R. In the example indicated, the total weight of PbCrO3 must be included in determining the threshold for both lead compounds and in determining the threshold for chromium compounds. In reporting the releases and other waste management of lead, only the stoichiometric weight of the lead in PbCrO3 released or otherwise managed as waste would be included. Likewise, only the chromium in PbCrO3 that is released and otherwise managed as a waste would be included on the Form R.</div></b><div style="visibility:hidden"></div></b>-
Chromium; Compound; Lead; Metal Compounds; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19183 19-183 183 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Chromium (Chromium Compounds); Compound (Compounds); Lead (Lead Compounds); Metal Compounds; Threshold Determination (Activity Threshold) 183. For Section 313 reporting requirements and threshold determinations, if a covered facility uses lead, lead chromate, and other chromium compounds, can they be considered separately or must they be combined into categories? When reporting releases and other waste management activities, must quantities of categories be determined as well?Threshold determinations for metal containing compounds are made separately from parent-metal threshold determinations because they are listed separately under Section 313. In the scenario presented in the question, the facility would apply the quantity of the lead metal manufactured, processed, or otherwise used to the appropriate threshold for lead. The facility would apply the quantities of the lead chromate manufactured, processed, or otherwise used to the appropriate threshold for lead compounds and would apply the quantities of the lead chromate and other chromium compounds manufactured, processed, or otherwise used to the appropriate threshold for chromium compounds. However, a facility may, once a threshold has been met individually, combine the parent metal and its metal compounds for reporting. In completing the Form R, only the weight of the parent metal (not the entire compound weight) is to be considered.</div></b><div style="visibility:hidden"></div></b>-
Activity Threshold; Compound; Facility; Form R; Fume or Dust; Metal Compounds; Metals; Zinc3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19184 19-184 184 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Activity Threshold (Threshold Determination); Compound (Compounds); Facility; Form R; Fume or Dust; Metal Compounds; Metals; Zinc 184. If a facility exceeds an activity threshold for both the parent metal and the metal compounds category for the same metal, can that facility file both chemicals on one EPCRA §313 Form R report?Only elemental metals without a chemical qualifier can be reported with their associated metal category compound on a combined Form R report. Elemental metals with qualifiers that are only reportable if they are manufactured, processed, or otherwise used in a specific form(s) cannot be reported with their associated metal compound category on the same Form R. For example, a facility that exceeds an activity threshold for both zinc (fume or dust) and zinc compounds must not report both zinc (fume or dust) and zinc compounds on the same Form R. Additional information on reporting metal category compounds and their parent metal can be found in the Toxic Chemical Release Inventory Reporting Forms and Instructions.</div></b><div style="visibility:hidden"></div></b>-
Compound; Metal Compounds; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19201 19-201 201 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Compound (Compounds); Metal Compounds; Threshold Determination (Activity Threshold) 201. We manufacture and use copper wire. We also use copper compounds in various parts of our processes. The Section 313 list contains both copper and copper compounds. Should we combine these categories for our determination of thresholds and reporting? Do we report the release and other waste management of copper compounds as copper metal?Copper and copper compounds are separate entries on the Section 313 list, and therefore threshold determinations should be made separately. Copper compounds are a listed category and will include the aggregate of all copper compounds (other than the free metal). For copper compounds, report releases and other waste management activities as copper (e.g., as the copper ion in wastewater), not as the total mass of copper compounds. If a facility exceeds thresholds for both the parent metal and compounds of the same metal, EPA allows the facility to file a combined report (e.g., one report for copper compounds and copper metal).</div></b><div style="visibility:hidden"></div></b>-
Compound; Metal Compounds; Process; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19203 19-203 203 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Compound (Compounds); Metal Compounds; Process (Processing; Processed; Processes); Threshold Determination (Activity Threshold) 203. An electroplating facility uses metal cyanide compounds in their electroplating operations. Are they processing or otherwise using those cyanide compounds? How do they determine whether they meet the threshold, and which threshold applies?The parent metal is plated onto a substance electrochemically. The metal compounds are processed, and the cyanide compounds are processed because the metal cyanide is the source of the metal that is plated and subsequently distributed in commerce. Metal cyanides are reportable as both cyanide compounds and metal cyanides. The total compound weight is applied for threshold determinations for both categories.</div></b><div style="visibility:hidden"></div></b>-
Compound; Metal Compounds; Multiple Chemical Category; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19204 19-204 204 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Compound (Compounds); Metal Compounds; Multiple Chemical Category; Threshold Determination (Activity Threshold) 204. An oxidation/reduction reaction that occurs as part of a waste treatment operation results in the formation of 2,500 pounds of lead chromate. How must a threshold determination be made for this compound?Lead chromate meets the criteria for both a lead compound and a chromium compound. In such cases, the total amount of the compound manufactured, processed, or otherwise used must be applied to the threshold determination for both metal compound categories. The weight of the entire compound, not the weight of the parent metal, is applied for the threshold determination of each metal compound category.</div></b><div style="visibility:hidden"></div></b>-
Chemical Qualifier; Compound3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19235 19-235 235 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Chemical Qualifier; Compound (Compounds) 235. In the Federal Register, (53 FR 4538; February 16, 1988) EPA describes cyanide compounds as X+CN- where X=H+ or any other group where a formal dissociation may occur; examples are KCN and Ca(CN)2. Are cyanide compounds that do not dissociate reportable?Cyanide compounds that do not dissociate are not reportable. However, dissociable cyanide compounds are not limited to the simple salts. Rather, this category includes all cyanide compounds for which dissociation upon release to the environment is expected to occur.</div></b><div style="visibility:hidden"></div></b>-
Ammonia; Chemical Conversion; Fertilizer; Mining; Nitrate Compounds3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19273 19-273 273 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Ammonia; Chemical Conversion (Activity Threshold); Fertilizer; Mining (Mines); Nitrate Compounds (Nitrates) 273. A mining facility applies a commercial fertilizer that contains dry ammonium nitrate to the land as part of a mine reclamation project. Is the facility required to count the ammonium nitrate toward the manufacturing threshold for the ammonia listing and nitrate compounds listing when it rains on the fertilizer?No. Ammonium nitrate is only converted to reportable chemicals when in solution (40 CFR Section 372.65) and in this case the solutions are not created until after the chemical has been released into the environment. Therefore, the facility would not have to report for this activity since facilities are not required to report on conversions that take place in the environment.</div></b><div style="visibility:hidden"></div></b>-
Compound; Metal Compounds; Metals; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19512 19-512 512 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Compound (Compounds); Metal Compounds; Metals; Threshold Determination (Activity Threshold) 512. For Section 313 reporting, a catalyst contains 61 percent total nickel, which includes 26 percent nickel metal and 35 percent nickel contained in compounds. Should the threshold determination be based on the 61 percent total nickel?No. The 61 percent total nickel cannot be used in the threshold determinations. Nickel compounds are a listed toxic chemical category; therefore, the full weight of nickel compounds (not just the 35 percent nickel contained in the compounds) must be used in the threshold determination for nickel compounds. A separate threshold determination is required for the nickel metal since nickel is a separately listed toxic chemical under Section 313. </div></b><div style="visibility:hidden"></div></b>-
Compound; Compound Category; Concentration Range; Metal Compounds; Waste Treatment; pH3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19513 19-513 513 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Compound (Compounds); Compound Category (Chemical Categories; Chemical Category); Concentration Range; Metal Compounds; Waste Treatment; pH 513. A covered facility uses chromium compounds in its electroplating operation, and as a result, a hexavalent chromate compound is generated. Are the hexavalent chromate compounds reportable under Section 313?The hexavalent chromate compounds are members of a reportable toxic chemical category, chromium compounds, and have been manufactured by the oxidation/reduction reaction that occurred in the electroplating operation. As a result, the total amount of the hexavalent chromate compounds produced must be included in the manufacturing threshold for chromium compounds. </div></b><div style="visibility:hidden"></div></b>-
Chromium; Compound; Metal Compounds3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19514 19-514 514 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Chromium (Chromium Compounds); Compound (Compounds); Metal Compounds 514. Are chromium compounds (e.g., chromic acid CAS number 11115-74-5 or chromic acetate CAS number 1066-30-4) reportable under Section 313? All chromium compounds are reportable. They must be aggregated together for purposes of threshold and maximum amount on-site calculations. However, release and other waste management amounts should be for the chromium metal portion only (see 40 CFR Section 372.25(h)).</div></b><div style="visibility:hidden"></div></b>-
Compound; Lead; Metal Compounds; Metals3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19515 19-515 515 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Compound (Compounds); Lead (Lead Compounds); Metal Compounds; Metals 515. A covered facility has determined that it needs to report under EPCRA section 313 for both elemental lead and lead compounds. Can this facility file one Form R that takes into account both the releases and other waste management activities of lead and lead compounds, or is it required to report separately?If a covered facility exceeds thresholds for both the parent metal and compounds of that same metal, it is allowed to file one joint Form R (e.g., one report for both lead compounds and elemental lead). EPA allows this because the release and other waste management information reported in connection with metal compounds will be the total pounds of the parent metal released and otherwise managed as a waste.</div></b><div style="visibility:hidden"></div></b>-
Compound; Lead; Metal Compounds; Release Reporting3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
<div style="visibility:hidden">19516 19-516 516 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories Compound (Compounds); Lead (Lead Compounds); Metal Compounds; Release Reporting 516. A covered facility processes both elemental lead and lead compounds. The facility exceeds the 100 pounds per year processing threshold for lead compounds, but not for elemental lead, and must submit a report for lead compounds only. When calculating releases and other waste management activities from the lead compounds, the owner/operator is only required to account for the weight of the parent metal released (40 CFR Section 372.25(h)). Should the facility account for both releases of lead from activities involving lead compounds and releases of lead from activities involving elemental lead?No. In the case when an activity threshold is exceeded only for lead compounds, the report is only required to be based on the releases and other waste management estimates of lead, the parent metal, from lead compounds only. Releases and other waste management estimates of lead resulting from activities involving elemental lead need not be included in the release and other waste management calculations. Conversely, if the facility were to exceed an activity threshold for only elemental lead, the report would only have to be based on releases and other waste management estimates from activities involving elemental lead only. </div></b><div style="visibility:hidden"></div></b>-
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