Questions and Answers

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Hydrogen Sulfide; Reporting Requirements3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19155 19-155 155 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Hydrogen Sulfide; Reporting Requirements 155. Hydrogen sulfide (H2S) was originally added to the list of TRI covered chemicals in 1993; however, dating back to 1994, there has been an administrative stay for reporting hydrogen sulfide under EPCRA §313. What is the current status of the administrative stay on EPCRA §313 reporting requirements for hydrogen sulfide?Hydrogen sulfide is included on the TRI list of chemicals reportable under EPCRA section 313 (40 CFR Part 372, Subpart D). Beginning with the 2012 reporting year (reports due July 1, 2013), the Administrative Stay is lifted and facilities are required to submit TRI reports for hydrogen sulfide. Additional information regarding the lifting of the administrative stay on hydrogen sulfide is available at the following URL:https://www.epa.gov/toxics-release-inventory-tri-program/lifting-administrative-stay-hydrogen-sulfide.</div></b><div style="visibility:hidden"></div></b>-
Activity Threshold; De minimis Exemption; Hydrogen Sulfide; Reporting Requirements3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19156 19-156 156 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Activity Threshold (Threshold Determination); De minimis Exemption; Hydrogen Sulfide; Reporting Requirements 156. The administrative stay for hydrogen sulfide (H2S) under EPCRA §313 was lifted in November 2011; therefore, facilities will be required to submit TRI reports for Reporting Year 2012 by July 1, 2013. Will there be any special applicability issues for the reporting of hydrogen sulfide?The reporting requirements for hydrogen sulfide have not changed from those that have been in place since it was originally listed in 1993. Therefore, facilities should consider the following information in determining applicability: a) Hydrogen sulfide is not a persistent bioaccumulative toxic (PBT) chemical. Therefore, it is subject to the standard activity thresholds of 25,000 pounds for manufacturing and processing and 10,000 pounds for otherwise use. b) Hydrogen sulfide is listed without a chemical qualifier; therefore, it is subject to reporting in all forms in which it is manufactured, processed, or otherwise used. c) For purposes of the de minimis exemption, the 1.0% level applies to hydrogen sulfide because it does not meet the Occupational Safety and Health Administrations definition of a carcinogen. Therefore, hydrogen sulfide is exempt in a mixture at a concentration lower than 1.0%. Additional information about the reporting of hydrogen sulfide and the lifting of the administrative stay are available at the following URL: https://www.epa.gov/toxics-release-inventory-tri-program/lifting-administrative-stay-hydrogen-sulfide.</div></b><div style="visibility:hidden"></div></b>-
Reporting Requirements3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19157 19-157 157 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Reporting Requirements 157. Acetonitrile was included on the original list of chemicals subject to the reporting requirements under EPCRA §313; however, EPA has since received two petitions to have it removed from the list of covered chemicals. What is the status of the most recent petition for the removal of acetonitrile from the list of chemicals subject to reporting requirements under EPCRA §313?On March 5, 2013, EPA published a notice in the Federal Register denying the petition to remove acetonitrile from the list of chemicals subject to TRI reporting requirements (78 FR 14241). After reviewing the available data on this chemical, EPA determined that acetonitrile does not meet the deletion criterion of EPCRA §313(d)(3). Specifically, EPA denied the petition because after a review of both the petition and available information, the Agency concluded that acetonitrile meets the listing criterion of EPCRA §313(d)(2)(B) due to its potential to cause death in humans. Further information about the petition is available at the following URL: https://www.epa.gov/toxics-release-inventory-tri-program/acetonitrile-petition.</div></b><div style="visibility:hidden"></div></b>-
Activity Threshold; Compound; Emissions Factors; Facility; Fuel; Lead; Manufacture; Otherwise Use; Process; Releases; Waste3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19188 19-188 188 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Activity Threshold (Threshold Determination); Compound (Compounds); Emissions Factors; Facility; Fuel; Lead (Lead Compounds); Manufacture (Manufactured; Manufacturing; Produce; Produced); Otherwise Use; Process (Processing; Processed; Processes); Releases (Released); Waste 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.</div></b><div style="visibility:hidden"></div></b>-
De minimis Exemption; Mixture; Threshold Determination; Xylene3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19419 19-419 419 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous De minimis Exemption; Mixture (Mixtures); Threshold Determination (Activity Threshold); Xylene 419. Xylene mixed isomers are present in two of a facility’s refined products. For EPCRA section 313 reporting, may the isomers be reported separately? For a mixture of the isomers, how are thresholds and de minimis to be determined? Reported separately, the facility exceeds thresholds but is below de minimis concentrations.All of the xylene isomers are individually listed under EPCRA section 313. In addition, there is a listing for xylene (mixed isomers) that covers any combination of xylene isomers. When the threshold and de minimis concentration for each isomer in the mixture are exceeded independently, the facility may report under the individual isomer listings or under the mixed isomers listing. When the threshold and/or de minimis for each isomer in the mixture are not exceeded independently, but are exceeded collectively, the facility should report under the CAS number for xylene (mixed isomers). Therefore, if a covered facility otherwise uses a mixture containing 8,000 pounds of ortho-xylene, 4,000 pounds of meta-xylene, and 2,000 pounds of para-xylene, the facility would report as xylene (mixed isomers) because it exceeded the 10,000-pound otherwise use threshold for xylenes (mixed isomers).</div></b><div style="visibility:hidden"></div></b>-
Toxic Chemical List3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19422 19-422 422 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Toxic Chemical List 422. On June 10, 2011, the National Toxicology Program (NTP) released its 12th Report on Carcinogens (RoC), which outlines chemicals that may pose a hazard to human health by virtue of their carcinogenity. Has EPA added any of the new chemicals from the 12th RoC to the EPCRA §313 TRI toxic chemical list?On November 7, 2013, EPA published a final rule adding ortho-nitrotoluene to the list of EPCRA §313 chemicals (78 FR 66848). After reviewing the 12th RoC, EPA concluded that ortho-nitrotoluene meets the EPCRA section 313(d)(2)(B) statutory listing criteria because it is “reasonably anticipated to be a human carcinogen.” This final rule is effective November 29, 2013, and will apply for the 2014 reporting year (reports due July 1, 2015). Additional information regarding the final rule, including the Federal Register notice, is available at the following URL: https://www.epa.gov/toxics-release-inventory-tri-program/addition-ortho-nitrotoluene-0.</div></b><div style="visibility:hidden"></div></b>-
Communities; Compound; PACs; PBT Chemicals; Toxic Chemical List3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19424 19-424 424 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Communities (Community); Compound (Compounds); PACs; PBT Chemicals; Toxic Chemical List 424. In 2005, the National Toxicology Program (NTP) released its 11th Report on Carcinogens (RoC), which outlines chemicals that may pose a hazard to human health by virtue of their carcinogenity. Has EPA added any of the chemicals from the RoC to the EPCRA §313 TRI toxic chemical list?On November 26, 2010, EPA expanded the TRI toxic chemical list by adding 16 chemicals classified as “reasonably anticipated to be a human carcinogen” by the National Toxicology Programs (NTP) Report on Carcinogens (75 FR 72727). After reviewing the NTPs report, EPA believes that these 16 chemicals meet the EPCRA §313(d)(2)(B) statutory listing criteria because they can reasonably be anticipated to cause cancer in humans. Twelve of the chemicals were listed individually, while the remaining four were added to the polycyclic aromatic compounds (PACs) category. The PACs category is a category of special concern because PACs are persistent, bioaccumulative, toxic (PBT) chemicals, and as such, they are likely to remain in the environment for a very long time, are not readily destroyed, and may build up or accumulate in the body. This rulemaking to expand the TRI toxic chemical list is a part of EPAs ongoing efforts to provide communities with more complete information on chemicals. The revised toxic chemical list is effective starting with reports due July 1, 2012, for Reporting Year 2011.</div></b><div style="visibility:hidden"></div></b>-
Chemical Category; Delimited Category; PACs; Release Reporting; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19494 19-494 494 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Chemical Category (Compound Category); Delimited Category; PACs; Release Reporting; Threshold Determination (Activity Threshold) 494. The EPCRA section 313 toxic chemical list contains delimited chemical categories. A delimited category includes a finite number of chemicals specifically designated by EPA to be included as part of that category. Are threshold determinations and release and other waste management calculations for these three delimited chemical categories different than threshold determinations and release and other waste management calculations for other EPCRA section 313 listed chemical categories?Threshold determinations are made in the same manner for both delimited and nondelimited categories. If a covered facility manufactures, processes, or otherwise uses more than one member of a listed chemical category, the total volume of all the members of the category must be counted towards the applicable activity threshold (40 CFR Section 372.27(d)). If an activity threshold is exceeded, the owner or operator of the facility is required to report under EPCRA section 313. The report must cover all non-exempt activities at the facility involving members of the category. For reporting on delimited categories, only the members that are specifically listed as part of the category are subject to EPCRA section 313 reporting. When reporting other nondelimited chemical categories, any unique chemical substance that contains the named category compound as part of that chemical’s structure, or any compound meeting the specified molecular formula, is subject to threshold determinations. In 1999, (64 FR 58666, October 29, 1999), EPA classified the PACs category as a PBT chemical category and lowered the reporting threshold to 100 pounds. In addition, EPA added two members to this category: benzo(j,k)fluorine (fluoranthene) and 3-methylcholanthrene. EPA has developed guidance to facilitate accurate reporting for PACs entitled Guidance for Reporting Toxic Chemicals: Polycyclic Aromatic Compounds Category, accessible from GuideME at: https://ofmpub.epa.gov/apex/guideme_ext/f?p=guideme:gd-list. The guidance contains a list of Chemical Abstract Service (CAS) numbers for the individual chemicals within the PACs category and a CAS number list of some mixtures that might contain chemicals within the PACs category. The dioxin and dioxin-like compounds category was also classified as a PBT chemical category and a reporting threshold of 0.1 gram was established. EPA has also developed guidance to facilitate accurate reporting for dioxin and dioxin-like compounds; Guidance for Reporting Toxic Chemicals with the Dioxin and Dioxin-like Compounds Category is available on GuideME at: https://ofmpub.epa.gov/apex/guideme_ext/f?p=guideme:gd-list.</div></b><div style="visibility:hidden"></div></b>-
Compound; Dioxin and Dioxin-like Compounds; Lead; PACs; PBT Chemicals; Pesticides3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19495 19-495 495 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Compound (Compounds); Dioxin and Dioxin-like Compounds (Dioxin); Lead (Lead Compounds); PACs; PBT Chemicals; Pesticides 495. What should I know about persistent bioaccumulative toxic (PBT) chemicals?Starting in 2000, EPA established more stringent reporting thresholds for persistent bioaccumulative toxic (PBT) chemicals originally on, or added to, the TRI chemical list. PBT chemicals are of particular concern not only because they are toxic, but also because they remain in the environment for long periods of time, are not readily destroyed, and build up or accumulate in body tissue. The TRI PBT chemicals include dioxin and dioxin-like compounds, lead and lead compounds, mercury and mercury compounds, polycyclic aromatic compounds (PACs), polychlorinated biphenyls (PCBs), hexabromocyclododecane (HBCD), and certain pesticides, among other chemicals. For more detailed information about PBT chemicals under the TRI program, visit https://www.epa.gov/toxics-release-inventory-tri-program/persistent-bioaccumulative-toxic-pbt-chemicals-rules-under-tri.</div></b><div style="visibility:hidden"></div></b>-
Chemical Deletion; New Chemicals; States; Toxic Chemical List; Tribes3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19496 19-496 496 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Chemical Deletion (Deleted Chemicals); New Chemicals; States (Tribes); Toxic Chemical List; Tribes 496. Who has been granted authority to add or delete chemicals from the TRI toxic chemical list under EPCRA section 313?Pursuant to EPCRA section 313(d), only EPA has the statutory authority to add or delete chemicals from the TRI toxic chemicals list. However, EPCRA section 313(e)(2) allows states and tribes to petition EPA to add or delete chemicals. If EPA receives a petition from a state or tribe that requests the addition of a particular chemical, EPA would have 180 days to respond with either the initiation of a rulemaking to add the chemical to the list or an explanation of why the petition does not meet the requirements to add a chemical to the list. If EPA does not respond within 180 days of receipt of a state or tribe’s petition to add a chemical, the chemical would be added to the list pursuant to EPCRA section 313(e)(2). Within 180 days of receipt of a state or tribe’s petition to delete a chemical, EPA would either initiate a rulemaking to delete the chemical or explain why EPA denied the petition; however, unlike the analogous process for petitions to add a chemical, the chemical would not be deleted within 180 days if EPA failed to respond to the petition. In addition, pursuant to EPCRA section 313(e)(1), any person may petition EPA to add or delete a chemical from the list of TRI toxic chemicals. If EPA receives a petition by a private citizen to add a chemical and EPA fails to respond within 180 days, the chemical would not necessarily be added. This result distinguishes citizen petitions to add a chemical from petitions to add a chemical by a state or tribe.</div></b><div style="visibility:hidden"></div></b>-
Chemical Qualifier3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19524 19-524 524 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Chemical Qualifier 524. A facility was advised by one supplier that aluminum oxide, CAS number 1344-28-1, is a listed toxic chemical under Section 313. The facility was advised by another supplier that this toxic chemical was on the toxic chemical list in error. Is aluminum oxide included on the toxic chemical list and therefore potentially reportable under Section 313?Only fibrous forms of aluminum oxide are reportable under Section 313. Other forms of aluminum oxide are not subject to reporting (55 FR 5220, February 14, 1990). </div></b><div style="visibility:hidden"></div></b>-
Chemical Qualifier3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19525 19-525 525 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Chemical Qualifier 525. A dinnerware manufacturer wants to know if she has to report aluminum oxide in her clay, which is a raw material for her product.Aluminum oxide in clay is usually part of another compound or mineral, such as kaolin, and is not present as a listed toxic chemical. In addition, it is unlikely the clay contains man-made, fibrous forms of aluminum oxide. Naturally occurring aluminum oxide, known as corundum, has a separate CAS number, 1302-74-5, and is not reportable.</div></b><div style="visibility:hidden"></div></b>-
Chemical Qualifier3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19526 19-526 526 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Chemical Qualifier 526. Are aluminosilicates reportable as aluminum oxide (fibrous forms)?Aluminosilicates, aluminoborosilicates, zeolites, aluminum silicate hydroxides, and other related materials are either naturally occurring or are prepared by fusion at high temperatures. As a result, these materials are not considered to be fibrous forms of aluminum oxide under Section 313 and are not subject to reporting. </div></b><div style="visibility:hidden"></div></b>-
Mixture3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19527 19-527 527 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Mixture (Mixtures) 527. For Section 313 purposes, is zeolite considered to be a mixture that contains aluminum oxide or is it considered to be a compound that is not a reportable substance?Zeolite is an aluminum silicate compound that is not reportable under Section 313. </div></b><div style="visibility:hidden"></div></b>-
Concentration; Mixture; Xylene3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19529 19-529 529 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Concentration; Mixture (Mixtures); Xylene 529. A covered facility processes two of the three xylene isomers in separate streams, along with an additional stream containing a mixture of xylene isomers of unknown concentrations. How would the facility determine if an activity threshold has been exceeded? How would the facility report the xylene on the Form R?The toxic chemical list at 40 CFR Section 372.65, contains four xylene listings (mixed isomers, ortho-, meta-, and para-xylene) that appear with their own CAS number. The CAS number specified for xylene (mixed isomers), 1330-20-7, applies to any combination of xylene isomers. The facility must make separate threshold determinations for each individual chemical listed at Section 372.65. If the thresholds are not exceeded for any of the individual xylene listings of Section 372.65, then the facility would not have to report on any releases of xylene at the facility. For example, if the facility processes, in separate streams, 10,000 pounds of ortho-xylene (CAS number 95-47-6), 10,000 pounds of para-xylene (CAS number 106-42-3), and 10,000 pounds of xylene in which the isomers are mixed in unknown concentrations (CAS number 1330-20-7), a threshold is not exceeded for any of the xylene listings. Therefore, no reports for xylene would be required. The quantities of the individual xylene listings processed by the facility should not be aggregated for the purposes of making threshold determinations. If the thresholds are exceeded for two or more of the individual isomer xylene listings, the facility has two choices when filling out the Form R. The facility may file separate Form Rs for each isomer or unique isomer mixture listed in Section 372.65, or the facility may file one combined report. For example, the facility processes, in separate streams, 30,000 pounds of ortho-xylene, 30,000 pounds of para-xylene, and 30,000 pounds of xylene where the isomers are mixed in unknown concentrations. Because the activity threshold for each of the three xylene listings is exceeded independently, the facility can report releases and other waste management activities from each of three listings separately on three different Form Rs (one for ortho-xylene, one for para-xylene, and one for the mixed isomers) or the facility can report all xylene releases and other waste management estimates on one Form R as xylene (mixed isomers). </div></b><div style="visibility:hidden"></div></b>-
Glycol Ethers Category3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19530 19-530 530 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Glycol Ethers Category 530. Although the category of glycol ethers requires reporting under Section 313, does diethylene glycol require reporting?Diethylene glycol is not subject to reporting. Glycol ethers, with the following structure, are reportable: R - (OCH2CH2)n - OR’, where: n = 1, 2, or 3; R = alkyl C7 or less, or R = phenyl or alkyl substituted phenyl; R’ = H or alkyl C7 or less; or OR’, consisting of a carboxylic acid ester, sulfate, phosphate, nitrate, or sulfonate. The R groups for this structure are unsubstituted alkyl or aryl groups. For diethylene glycol, neither R nor R’ contain alkyl or aryl groups and thus it is not subject to reporting under Section 313. For more information refer to EPA’s document entitled, Toxics Release Inventory: List of Toxic Chemicals Within the Glycol Ethers Category (EPA-745-R-95-006).</div></b><div style="visibility:hidden"></div></b>-
Glycol Ethers Category3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19531 19-531 531 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Glycol Ethers Category 531. Are dipropylene glycol ethers having a RNOC3H6OC3H6OR structure considered a glycol ether for Section 313 toxic chemical reporting?Dipropylene glycol ethers are not Section 313 reportable glycol ethers since it has (OCH2CH2CH2)n or (OCH2CH(CH3))n instead of (OCH2CH2)n in its structure. Propylene glycol-based ethers are not covered by this category.</div></b><div style="visibility:hidden"></div></b>-
Glycol Ethers Category3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19532 19-532 532 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Glycol Ethers Category 532. Is ethylene glycol mono butyl ether a Section 313 chemical reportable as a glycol ether?Using the structural definition of glycol ethers as they appear in the final rule, ethylene glycol mono butyl ether is reportable under Section 313. R - (OCH2CH2)n - OR’ In this case R is equal to butyl, (CH3CH2CH2CH2-); R’ = H; and n = 1.</div></b><div style="visibility:hidden"></div></b>-
Glycol Ethers Category; Toxic Chemical List3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19533 19-533 533 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Glycol Ethers Category; Toxic Chemical List 533. Effective November 29, 2004, EPA amended the list of hazardous air pollutants (HAP) contained in Section 112(b)(1) of the Clean Air Act (CAA) by removing the compound ethylene glycol monobutyl ether (EGBE), also known as 2-butoxyethanol (Chemical Abstract Service (CAS) Number 111-76-2) from the group of glycol ethers. Is EGBE still subject to EPCRA section 313 TRI reporting under the certain glycol ethers chemical category?Although EGBE was removed from the list of HAPs under the CAA regulations, it was not removed from the TRI toxic chemical list. Therefore, it continues to be a part of the certain glycol ethers category of chemicals subject to TRI reporting. Additional information for reporting glycol ethers under TRI is available in the document entitled Toxics Release Inventory - List of Toxic Chemicals within the Glycol Ethers Category (EPA745-R-00-004; December 2000).</div></b><div style="visibility:hidden"></div></b>-
Mixture3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19534 19-534 534 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Mixture (Mixtures) 534. Is polyethylene considered a mixture of ethylene and its polymer, the components of which must be counted for purposes of reporting under Section 313 of EPCRA?Polyethylene is not a listed chemical and thus is not subject to reporting under Section 313. A mixture is any combination of two or more chemicals if the combination is not, in whole or in part, a result of a chemical reaction. If the combination resulted from a reaction but could have been produced without a chemical reaction, it is still treated as a mixture. Thus, since polyethylene is the result of chemical reaction, it is not a mixture under EPCRA section 313. Any EPCRA section 313 listed toxic chemicals used in the manufacture of polyethylene should be evaluated against the proper Section 313 activity threshold.</div></b><div style="visibility:hidden"></div></b>-
Mixture3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19535 19-535 535 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Mixture (Mixtures) 535. A covered facility uses hydraulic fluid which is 95 percent mineral oil and 5 percent other unspecified components. Does the facility have any Section 313 chemicals to report?Mineral oil is a highly refined mixture of saturated C15 to C50 hydrocarbons. Barring any information to the contrary, it is unlikely that mineral oil contains significant quantities of any Section 313 chemicals. </div></b><div style="visibility:hidden"></div></b>-
Toxic Chemical List3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19536 19-536 536 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Toxic Chemical List 536. Are vinyl chloride, a listed toxic chemical, and polyvinyl chloride, not listed, the same thing? Polyvinyl chloride is not a listed toxic chemical and does not need to be reported (see 40 CFR Section 372.65). It is a polymer of vinyl chloride. Only unreacted vinyl chloride mixed with the polymer should be included in threshold determinations and release and other waste management calculations.</div></b><div style="visibility:hidden"></div></b>-
Toxic Chemical List3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19537 19-537 537 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Toxic Chemical List 537. Are toxic chemical monomers such as acrylonitrile, butadiene and styrene, which are contained in a plastic copolymer known as ABS, reportable under Section 313? These chemicals are monomers that react to make the ABS copolymer that is not reportable under Section 313 (see 40 CFR Section 372.65). However, if any unreacted acrylonitrile, butadiene, or styrene monomers are present in the ABS copolymer in excess of de minimis concentrations then they are reportable.</div></b><div style="visibility:hidden"></div></b>-
SDS3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19538 19-538 538 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous SDS 538. A covered facility uses a toxic chemical known to them as DOP, which they think is n-dioctyl phthalate. N-dioctyl phthalate has the CAS number 117-84-0 and is not on the Section 313 list. However, the SDS from their supplier states that the toxic chemical is called DEHP or DOP and has the CAS number 117-81-7. DEHP is di(2-ethylhexyl) phthalate on the Section 313 list. Should this chemical be reported?DOP is a commonly used acronym for both di(2-ethylhexyl) phthalate (DEHP) and n-dioctyl phthalate (DNOP). DOP is also listed as a synonym for DEHP in the Section 313 Common Synonyms document. However, as the supplier provided the acronym DEHP and the CAS number is 117-81-7, the facility has sufficient information to distinguish between DNOP and DEHP and thus should report for DEHP.</div></b><div style="visibility:hidden"></div></b>-
Asbestos; CAS Number3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19539 19-539 539 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Asbestos; CAS Number 539. Asbestos, with CAS number 1332-21-4, is a listed toxic chemical under Section 313. The synonym list does not contain reportable asbestos forms. A covered facility uses the following forms of asbestos and would like to know if they are reportable: Actinolite (CAS number 77536-66-4), Amosite (CAS number 12172-73-5), Anthophyllite (CAS number 17068-78-9), Chrysotile (CAS number 12001-29-5), Crocidolite (CAS number 12001-28-4), and Tremolite (CAS number 77536-68-6).The Section 313 listing for asbestos (CAS number 1332-21-4) includes specific forms of asbestos, such as those mentioned above, that have their own individual CAS numbers. Therefore, those types of asbestos are reportable as long as they are manufactured, processed, or otherwise used in the friable form.</div></b><div style="visibility:hidden"></div></b>-
-3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19541 19-541 541 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous 541. Is paraformaldehyde, CAS number 30525-89-4, reportable as formaldehyde under Section 313?No. Paraformaldehyde is hydrated polymerized formaldehyde, a solid material that is different from formaldehyde. At ambient temperature, vaporization occurs, emitting formaldehyde gas. Though paraformaldehyde itself is not reportable, any formaldehyde manufactured as a gas or a solution during the manufacture, processing, or otherwise use of paraformaldehyde must be applied to any threshold determination for formaldehyde. </div></b><div style="visibility:hidden"></div></b>-
De Minimis; Mixture; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19542 19-542 542 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous De Minimis; Mixture (Mixtures); Threshold Determination (Activity Threshold) 542. A facility receives a chemical mixture, 70 percent of which is toluene diisocyanate (TDI). Of this 70 percent, 80 percent is 2,4-TDI, with CAS number 584-84-9, and 20 percent is 2,6-TDI, with CAS number 91-08-7. The CAS number that appears on the SDS for TDI is 26471-62-5. How should the facility report?CAS number 26471-62-5 covers the mixture of the 2,4- and 2,6-TDI isomers. The 2,4- and 2,6-TDI isomers are also individually listed under EPCRA section 313. When the threshold quantity and de minimis concentration for each isomer in the mixture are exceeded independently, the facility may report under the individual isomer listings or under the mixed isomers listing. When the threshold quantity and/or de minimis for each isomer in the mixture are not exceeded independently, but are exceeded collectively, the facility should report under the CAS number for TDI (mixed isomers).</div></b><div style="visibility:hidden"></div></b>-
Mixture; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19544 19-544 544 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Mixture (Mixtures); Threshold Determination (Activity Threshold) 544. According to the Chemical Abstract Service (CAS), the Chemical Abstracts Registry name for CAS number 26471-62-5 is 'benzene, 1,3-diisocyanatomethyl-.' The structural formula that describes this CAS number is as follows: This name and structure imply only that the isocyanate groups must be one/three with respect to one another and that the position of the methyl group is not known. It should be noted that neither the name nor the structure imply that there is necessarily a mixture of chemicals. The EPCRA section 313 list of toxic chemicals (40 CFR Section 372.65) includes CAS number 26471-62-5 with the name 'toluene diisocyanate (mixed isomers).' This name implies no positional relationship of the isocyanate groups with respect to each other or to the methyl group. In addition, the name seems to imply that there must necessarily be a mixture of compounds for this listing to apply. For the purposes of EPCRA section 313 reporting, what compounds are reportable under the CAS number 26471-62-5?The chemical name 'benzene, 1,3-diisocyanatomethyl-' is listed as a synonym for 'toluene diisocyanate (mixed isomers)' under CAS number 26471-62-5 in EPA’s document Common Synonyms For Chemicals Listed Under Section 313 of the Emergency Planning and Community Right-To-Know Act, EPA 745-R-95-008, March 1995. For purposes of reporting under EPCRA section 313, 'toluene diisocyanate (mixed isomers)' includes any possible mixture of any toluene diisocyanates in which the isocyanate groups are separated by one carbon in the ring (i.e., are one/three to each other). This listing includes the 2,4-, 2,6-, and 3,5- isomers of toluene diisocyanate (TDI). TDI is commonly manufactured as a mixture of isomers (e.g., an 80:20 mixture of 2,4- and 2,6-TDI). Even if the mixture is made up of the specifically listed isomers (i.e., 2,4- and 2,6-TDI), the listing 'toluene diisocyanate (mixed isomers)' still applies. The 'mixed isomer' listing is meant to include any mixture that contains two or more of the toluene diisocyanate isomers (i.e., 2,4-, 2,6-, or 3,5-TDI). The specifically listed 2,4- and 2,6- TDI isomers should be reported individually if not present as a mixture of TDI isomers. If, however, the individual thresholds for the pure TDI isomers are exceeded, the covered facility may file a single report for TDI (mixed isomers) and include the total quantity released or otherwise managed as waste.</div></b><div style="visibility:hidden"></div></b>-
CAS Number3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19545 19-545 545 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous CAS Number 545. A facility processes methylenebis-phenylisocyanate abbreviated MDI. MDI is listed under the EPCRA section 313 diisocyanates category with the CAS number 101-68-8. The MDI purchased by the facility, however, has the CAS number 26447-40-5. How should the facility treat this material with regard to Section 313 reporting requirements?The EPCRA section 313 listed chemical and the purchased chemical are not necessarily the same chemical. The purchased chemical is termed by the Chemical Abstract Service as an incompletely defined substance that may be or may contain the listed chemical. The facility must use all available information (e.g., supplier notification information), to identify the amount of the listed toxic chemical present in the purchased material for threshold determinations and release and other waste management calculations. If this material does contain MDI, the quantity of MDI present should be included in all threshold calculations for the diisocyanates category.</div></b><div style="visibility:hidden"></div></b>-
Activity Threshold; Ammonia; Chemical Qualifier; Release Reporting3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19547 19-547 547 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Activity Threshold (Threshold Determination); Ammonia; Chemical Qualifier; Release Reporting 547. A covered facility processes an aqueous ammonia solution from water-dissociable ammonium salts in tanks and open vats. Evaporative losses occur at several points during processing. Are these evaporative losses considered releases of aqueous ammonia or anhydrous ammonia for purposes of EPCRA section 313 reporting?Evaporation and drying losses from aqueous ammonia solutions result in the release of anhydrous ammonia, which is 100 percent reportable under the EPCRA section 313 ammonia listing. Although EPA modified the ammonia listing on June 30, 1995 (60 FR 34172), the modification only limits the quantity of aqueous ammonia that is reportable. The modification does not apply to anhydrous ammonia, which remains 100 percent reportable. Owners or operators must still include all anhydrous ammonia manufactured, processed, or otherwise used at a covered facility in threshold determinations and release and other waste management calculations. Anhydrous ammonia generated through the evaporation or drying of aqueous ammonia solutions derived from water-dissociable ammonium salts or other sources must be counted toward the applicable activity threshold. For example, if a facility processes aqueous ammonia, it has processed 100 percent of the aqueous ammonia in that solution. If the ammonia stays in solution, then 10 percent of the total aqueous ammonia is counted toward thresholds. If there are any evaporative losses of anhydrous ammonia, then 100 percent of those losses must be counted toward the processing threshold. If the manufacturing, processing, or otherwise use thresholds for the ammonia listing are exceeded, the facility must report 100 percent of these evaporative losses in Part II, Sections 5 and 8 of the Form R.</div></b><div style="visibility:hidden"></div></b>-
Ammonia; Chemical Qualifier; Release Reporting; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19549 19-549 549 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Ammonia; Chemical Qualifier; Release Reporting; Threshold Determination (Activity Threshold) 549. Ammonia is included on the EPCRA section 313 toxic chemical list with the qualifier “includes anhydrous ammonia and aqueous ammonia from water dissociable ammonium salts and other sources; 10 percent of total aqueous ammonia is reportable under this listing” (40 CFR Section 372.65). As this qualifier indicates, the quantities applied to EPCRA section 313 threshold determinations depend on the specific form of ammonia manufactured, processed, or otherwise used. Release and other waste management calculations also depend on the form of ammonia released or otherwise managed as waste. How does one distinguish between anhydrous ammonia and aqueous ammonia for the purpose of this listing? What are the differences in threshold determinations and release and other waste management calculations for the two forms of ammonia?The term “anhydrous” means “lacking water,” whereas “aqueous” means “dissolved in water.” Anhydrous ammonia (in either the gas or compressed liquid state) may, however, contain a small amount of water. The presence of water in anhydrous ammonia does not constitute aqueous ammonia unless the amount of water present is sufficient to dissolve the ammonia. If ammonia is not actually dissolved in water, then the ammonia must be considered anhydrous. Facilities must be able to distinguish between anhydrous ammonia and aqueous ammonia when making threshold determinations and release and other waste management estimates because different percentages of the total amount of ammonia apply depending on the form of ammonia present. If anhydrous ammonia is manufactured, processed, or otherwise used, then 100 percent of the anhydrous ammonia must be counted when determining whether an activity threshold has been exceeded. If the facility exceeds an activity threshold for ammonia (anhydrous and/or aqueous), then all of the anhydrous ammonia released and otherwise managed as wastes must be included in the facility's release and other waste management calculations. Total aqueous ammonia includes both the ionized (NH4+) and un-ionized (NH3) forms of ammonia present in aqueous solutions. When a facility manufactures, processes, or otherwise uses aqueous ammonia, it is conducting a threshold activity on 100 percent of the aqueous ammonia. However, the facility owner or operator counts only 10 percent of the total aqueous ammonia involved in a covered activity when making threshold determinations. Similarly, when estimating annual releases and other waste management estimates of ammonia from a facility, only 10 percent of the total aqueous ammonia must be included in the calculations. Dissolving water-dissociable ammonium salts in water constitutes the manufacturing of aqueous ammonia. According to the ammonia qualifier, 10 percent of the total amount of aqueous ammonia created must be applied toward the 25,000-pound manufacture threshold as well as the processing or otherwise use threshold, depending on the use of the aqueous ammonia at the facility. However, since 100 percent of the anhydrous form of ammonia is reportable under the ammonia listing, all anhydrous ammonia used to make aqueous ammonia must be applied toward either the processing or otherwise use threshold, depending on the use of the aqueous ammonia solution at the facility.</div></b><div style="visibility:hidden"></div></b>-
Ammonia; Chemical Qualifier; Concentration; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19550 19-550 550 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Ammonia; Chemical Qualifier; Concentration; Threshold Determination (Activity Threshold) 550. An EPCRA section 313 covered facility maintains a Safety Data Sheet (SDS) for ammonium hydroxide (CAS number 1336-21-6). The SDS lists the concentration of total ammonia in the ammonium hydroxide at 29 percent. To assist covered facilities in calculating total ammonia in aqueous solutions, EPA has published a guidance document titled EPCRA section 313 Guidance for Reporting Aqueous Ammonia, which lists NH3 equivalent weight percentages for chemical sources of aqueous ammonia. Ammonium hydroxide is listed as a chemical source of aqueous ammonia consisting of 48.59 percent total aqueous ammonia. When calculating the weight of total aqueous ammonia from ammonium hydroxide, should a facility use the percentage on the SDS or the percentage in the Agency's guidance document? When calculating the weight of total aqueous ammonia in other solutions of aqueous ammonia, what percentage should a facility use if given the choice between EPA’s guidance document and solution-specific information?The chemical ammonium hydroxide (NH4OH) is a misnomer. It is a common name used to describe a solution of ammonia in water (i.e., aqueous ammonia), typically a concentrated solution of 28 to 30 percent ammonia. EPA has consistently responded to questions regarding the reportability of these purported ammonium hydroxide solutions under the EPCRA section 313 ammonia listing by stating that these are 28 to 30 percent solutions of ammonia in water and that the solutions are reportable under the EPCRA section 313 ammonia listing. For a more detailed discussion, see page 34175 of the Federal Register final rule of June 30, 1995 (60 FR 34172). Facilities should use the percent total ammonia specified on the label of ammonium hydroxide solutions they purchase to determine the total ammonia content in these solutions. Ammonium hydroxide has the chemical formula NH4OH; however, as mentioned above, strong evidence indicates that the species NH4OH does not exist. Bottles of concentrated aqueous ammonia purchased from chemical supply companies are almost always labeled ammonium hydroxide. These solutions primarily consist of molecules of NH3 dissolved in water (along with small amounts of ionized ammonia). The 48.59 percent listed for ammonium hydroxide is based on the ammonia weight of the chemical formula NH4OH, not the actual concentration of total ammonia in ammonium hydroxide solutions. The actual concentration may vary depending upon the amount of NH3 used to make the solution. Thus, this may not accurately reflect the actual weight of total aqueous ammonia in any given solution labeled ammonium hydroxide. The percentages, reported in the document as NH3 equivalent weight percentages for chemical sources, are the precise percentages of total ammonia (expressed as NH3 equivalent weights) contained in each chemical listed based on the molecular formula for each chemical. Except for ammonium hydroxide, these numbers are exact for the pure chemical and do not vary. Facilities can use these numbers to calculate how much total ammonia will be in aqueous solutions made from these chemicals. If more specific information on the actual concentration of total ammonia in an aqueous solution is available from another source, such as an SDS label, or measurement, facilities can use this information rather than performing the calculations prescribed in the EPC</div></b><div style="visibility:hidden"> performing the calculations prescribed in the EPCRA Section 313 Guidance for Reporting Aqueous Ammonia.</div></b>-
Ammonia3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19551 19-551 551 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Ammonia 551. Do ammonium salts such as ammonium chloride need to be reported under EPCRA Section?Water dissociable ammonia salts, such as ammonium chloride, are reportable if they are placed in water. When ammonium salts are placed in water, reportable aqueous ammonia is manufactured. Ammonia (not ammonium salts) is on the list of toxic chemicals with the qualifier: 'includes anhydrous ammonia and aqueous ammonia from water dissociable ammonium salts and other sources; 10 percent of total aqueous ammonia is reportable under this listing.' As indicated in this qualifier, all aqueous ammonia solutions from water dissociable ammonium salts are covered by the ammonia listing. For example, ammonium chloride is a water dissociable ammonium salt. Reportable aqueous ammonia will be manufactured when it is placed in water. Ten percent of the total ammonia present in an aqueous solution containing ammonium chloride must be included in threshold determinations and release and other waste management calculations. </div></b><div style="visibility:hidden"></div></b>-
Emissions Factors; Hydrogen Sulfide; Releases; Waste; Wastewater Treatment; Water Treatment3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19553 19-553 553 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Emissions Factors; Hydrogen Sulfide; Releases (Released); Waste; Wastewater Treatment; Water Treatment 553. Beginning with Reporting Year (RY) 2012, facilities that manufacture or process hydrogen sulfide (H2S) in quantities that exceed 25,000 lb annually or otherwise use the chemical in quantities that exceed 10,000 pounds annually are required to report the quantities they release or otherwise manage as waste management to the Environmental Protection Agency’s (EPA) Toxics Release Inventory (TRI) Program. Many facilities will estimate these reportable quantities. What resources or emissions factors are available to assist in these estimations? Will EPA develop a hydrogen sulfide chemical guidance document for estimating threshold and release/waste management quantities of hydrogen sulfide?EPA does not plan to issue a specific guidance document for estimating threshold and release/waste management quantities of hydrogen sulfide at this time. As with all Emergency Planning and Community Right-To-Know (EPCRA) § 313 chemicals, facilities may use their best readily available data (including monitoring data) pursuant to EPCRA § 313(g)(2). When data are not readily available, EPCRA allows facilities to use “reasonable estimates” of the amounts involved. Further guidance regarding “reasonable estimates” can be found in Q&A # 469-475 and 681, available at: https://www.epa.gov/toxics-release-inventory-tri-program/1998-tri-reporting-qa-document. Facilities must retain documentation of calculations used to determine threshold and reporting quantities, along with copies of their submitted Form R or A, for the record retention period of three (3) years. Facilities may use mass balance calculations, published emissions factors, and/or engineering calculations and best judgment to create estimates for TRI reporting purposes. Below, EPA has listed some published emissions factors and information on federal and state limits on ambient hydrogen sulfide concentrations that may be useful in estimating releases of hydrogen sulfide: 1) Estimating Hydrogen Sulfide Releases at Petroleum Refineries: Consult the Canadian National Pollutant Release Inventory (NPRI) developed document, available at: http://www.canadianfuels.ca/website/media/PDF/Environmental%20Stewardship/Guidance%20Material/Canadian-Fuels_CoP_Rev15_Final_Report.pdf; 2) Estimating Hydrogen Sulfide Releases at Wastewater Treatment Plants: Consult the NPRI developed document, available at: http://www.ec.gc.ca/inrp-npri/86E3D932-F4A2-4584-B52A-7B85D797BCFA/Waste_Water_2002_English.pdf (Wastewater Treatment Plants: pages: 8-11); 3) Estimating Hydrogen Sulfide Releases from Aeration Basins: Consult the California Air Toxics Emissions Factor for Hydrogen Sulfide from Aeration Basins, available at: https://www.arb.ca.gov/research/apr/past/96-333_1_pt2.pdf; 4) Estimating Hydrogen Sulfide in Aqueous Solution: Consult the temperature and pH conditions cited in Method 4500-S2 - Sulfide in Standard Methods for the Examination of Water and Waste Water (https://www.nemi.gov/methods/method_summary/7418/). Please note that facilities only need to report the portion that is hydrogen sulfide and can exclude the portion that is sulfide ion. Other methods may also be applicable; 5) Estimating Hydrogen Sulfide in Air Emissions: Consult AP-42, available at: https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-compilation-air-emissions-factors; 6) Other: </div></b><div style="visibility:hidden">2-compilation-air-emissions-factors; 6) Other: Agency for Toxics Substances and Disease Registry (ATSDR) ToxGuide - The ToxGuide factsheet provides some summary information on typical environmental levels of hydrogen sulfide and also provides some health-based screening levels that have been established by ATSDR, available at: https://www.atsdr.cdc.gov/toxguides/toxguide-114.pdf. ATSDR Toxicological Profile: This is the more detailed technical document that is summarized in the ToxGuide, available at https://www.atsdr.cdc.gov/ToxProfiles/tp.asp?id=389&tid=67.</div></b>-
CAS Number; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19554 19-554 554 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous CAS Number; Threshold Determination (Activity Threshold) 554. Must a facility consider the use of the radioactive Cobalt-60 (CAS number 10198-40-0) in its threshold calculations for cobalt (CAS number 7440-48-4)?Cobalt-60 with CAS number 10198-40-0 is not on the list of toxic chemicals under EPCRA section 313. As such, Cobalt-60 is not reportable under EPCRA section 313. The listed toxic chemical is cobalt with CAS number 7440-48-4.</div></b><div style="visibility:hidden"></div></b>-
Chemical Category; Compound; Nitrate Compounds; Reporting Requirements3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19555 19-555 555 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Chemical Category (Compound Category); Compound (Compounds); Nitrate Compounds (Nitrates); Reporting Requirements 555. EPCRA section 313 requires covered facilities to report information on releases and other waste management of TRI-listed chemicals. Are nitrite compounds considered a listed toxic chemical category or are any individual nitrite compounds TRI-listed for the purposes of Section 313 threshold and release and waste management determinations?The toxic chemical release reporting requirements apply to chemicals and chemical categories listed in 40 CFR §372.65. Nitrite compounds are not included in the nitrate compounds toxic chemical category, and there is no specific “nitrite compounds” category. However, one nitrite compound, sodium nitrite, is individually listed as a toxic chemical in §372.65. Therefore, although nitrite compounds are not covered as a whole under TRI, sodium nitrite (a nitrite compound) is listed in 40 CFR §372.65. Facilities subject to the TRI reporting requirements that manufacture, process or otherwise use sodium nitrite in quantities that exceed a threshold for any of these activities and meet all other reporting requirements under EPCRA section 313 are required to report on sodium nitrite.</div></b><div style="visibility:hidden"></div></b>-
Reporting Requirements3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19556 19-556 556 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Reporting Requirements 556. On September 30, 2014, EPA published a rule to finalize the addition of a nonylphenol category to the list of toxic chemicals subject to TRI reporting under EPCRA §313 (79 FR 58686). Does this mean that all nonylphenols are subject to EPCRA §313 reporting?EPA listed the nonylphenol category as a delimited category defined by a specific list of chemical names and Chemical Abstract Service (CAS) Registry Numbers. Therefore, only the following six listed chemicals are reportable under the nonylphenol category for the purposes of TRI reporting: 4-Nonylphenol (CAS 104—40—5), Isononylphenol (CAS 11066-49-2), Nonylphenol (CAS 25154-52-3), 4-Isononylphenol (CAS 26543-97-5), 4-Nonylphenol, branched (CAS 84852-15-3), and Nonylphenol, branched (CAS 90481-04-2). This final rule is effective on September 30, 2014, and applies for the reporting year beginning January 1, 2015 (reports due July 1, 2016). Additional information, including the final rule, is available at the following URL: https://www.epa.gov/toxics-release-inventory-tri-program/addition-nonylphenol-category.</div></b><div style="visibility:hidden"></div></b>-
Chemical Category; Waste Treatment3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19557 19-557 557 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Chemical Category (Compound Category); Waste Treatment 557. Waste containing barium chloride is shipped off-site to a RCRA treatment, storage, or disposal (TSD) facility. The TSD facility treats the barium chloride, converting it to barium sulfate. The barium sulfate is stabilized and subsequently disposed. Since barium sulfate is excluded from the EPCRA section 313 barium compounds category, should the barium chloride be reported as shipped off-site for treatment or transferred off-site for disposal?Barium chloride is being converted into a chemical that is not reportable under EPCRA section 313. Therefore, the barium chloride would be considered to be treated for destruction. The barium chloride should be reported in Section 6.2 as transferred off site for treatment. M69 'other waste treatment' should be used. Despite the fact that barium chloride is a metal compound, the quantity of barium chloride transferred off-site should be reported in Section 8.7 rather than Section 8.1. The waste management of barium chloride is reported this way in Section 8 because the metal compound that barium chloride is converted to (barium sulfate) is not reportable and thus the barium chloride can be considered destroyed. The following is effective starting January 1, 1998: The TSD facility receiving the barium chloride should apply the quantity of the barium chloride that is converted to barium sulfate to the otherwise use threshold because it received the barium chloride from off-site for purposes of waste management and the facility treated the barium chloride for destruction (a listed chemical converted into a non-listed chemical). The TSD should also report the quantity of barium chloride that was treated for destruction in Section 8.6 (Quantity Treated On-site). It should also report any other releases or other waste management activities associated with the treatment for destruction of this toxic chemical.</div></b><div style="visibility:hidden"></div></b>-
Mixture; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19559 19-559 559 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Mixture (Mixtures); Threshold Determination (Activity Threshold) 559. A covered petroleum refinery manufactures naphtha from crude oil. A paraffin, olefin, naphthalene and aromatics (PONA) analysis revealed that the naphtha contains 2.5 percent by weight of C9 alkylbenzenes. Only two out of a possible eight C9 alkylbenzenes are reportable under Section 313. How would this manufacturer calculate the Section 313 reporting threshold for the generic chemical name category of C9 alkylbenzenes in this instance?The facility should not report for the generic mixture name, such as C9 alkylbenzenes, but for the specific chemical. Since the facility does not know the concentration of each chemical in the naphtha, and assuming 2.5 percent as the upper bound for each is unrealistic, the facility should assume that each listed C9 alkylbenzene is present and divide the concentration evenly between the eight. </div></b><div style="visibility:hidden"></div></b>-
CAS Number3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19563 19-563 563 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous CAS Number 563. The Chemical Abstract Service (CAS) maintains a computerized filing system that contains two main index files. The chemical abstract file provides bibliographic information referencing chemicals appearing in over 9,000 journals, papers, and symposiums from 1967 to the present. The chemical abstract file is an important tool for people interested in learning about the research, patents, and uses for specific chemicals. The chemical registry number file assigns CAS registry numbers to unique chemicals for purposes of identification. Assigning a CAS number to a particular chemical facilitates managing and regulating that chemical by universally identifying it with a specific number. Only one CAS number is assigned to each chemical and under EPCRA section 313, only one CAS number is listed per toxic chemical. If chemicals are to be assigned only one CAS number, why are some chemicals listed with multiple Chemical Abstract Service (CAS) numbers in 40 CFR Table 302.4 and the Title III List of Lists (EPA 550-B-98-017)?There are two possible reasons for a chemical to have multiple numbers. The CAS numbers could refer to different forms of a chemical where each is considered unique for its particular properties and characteristics. The CAS registry number file includes the registry number, synonyms, chemical structure, and molecular formula for each chemical recorded in the file. If specific research has been done on a particular form of a chemical, a separate CAS number may be assigned to that particular form to facilitate the search process in the CAS file. For example, sodium hypochlorite is listed with two CAS numbers, 7681-52-9 and 10022-70-5. The former refers to the sodium salt form of hypochlorous acid, sodium hypochlorite, while the latter refers to the pentahydrate form of sodium hypochlorite. Both forms could be called sodium hypochlorite, thus sodium hypochlorite has, in effect, two CAS numbers. A chemical may also be listed with multiple CAS numbers when multiple numbers have been inadvertently assigned to the same chemical. This multiple assignment can occur when forms of a chemical are originally believed to be unique, but after further review by chemists, are identified as the same chemical. In this case, all the CAS numbers are cross-referenced, allowing the chemical to be located with any assigned number. The misassigned numbers are deleted as registry numbers, but remain on file for referencing purposes. The CAS number first assigned is the more accurate number to use when denoting the chemical. Although all of the CAS numbers will find the chemical, only the more accurate number will prompt the CAS registry file system to display the name, synonyms, and characteristics associated with the chemical. Chromic acid, listed with CAS numbers 1115-74-5 and 7738-94-5, illustrates this situation. After further review by chemists, CAS number 1115-74-5 was deleted as a registry number, but remains on file for future reference. CAS number 7738-94-5 is the more accurate number to identify chromic acid because it was the first registry number assigned.</div></b><div style="visibility:hidden"></div></b>-
Ammonia; Maximum Amount On-Site3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19792 19-792 792 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Ammonia; Maximum Amount On-Site 792. Ammonia is included on the TRI toxic chemical list with the qualifier “includes anhydrous ammonia and aqueous ammonia from water dissociable ammonium salts and other sources; 10 percent of total aqueous ammonia is reportable under this listing.” For the purposes of reporting the maximum amount of the TRI chemical on-site at any time during the calendar year (Part II, Section 4 of the Form R), should the facility follow the 10% qualifier rule and report only 10% of the total aqueous ammonia on-site?When determining the maximum amount on-site for Part II, Section 4 of the Form R, the facility only has to consider the reportable form of a chemical. Therefore, for aqueous ammonia, the facility should report 10% of the maximum amount of total aqueous ammonia on-site at any time during the calendar year. In addition, the facility must report 100% of the maximum amount of anhydrous ammonia in this section.</div></b><div style="visibility:hidden"></div></b>-
Manufacture; Mixture; Supplier Notification3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Miscellaneous
<div style="visibility:hidden">19840 19-840 840 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Miscellaneous Manufacture (Manufactured; Manufacturing; Produce; Produced); Mixture (Mixtures); Supplier Notification (Supplier Notice) 840. Why is supplier notification not required for isopropyl alcohol (CAS 67-63-0) and saccharin (CAS 81-07-2)?Supplier notification is not required because isopropyl alcohol and saccharin have a manufacturing qualifier. Facilities that only process or otherwise use either of these TRI chemicals are not required to file TRI reports (40 CFR Section 372.65). Therefore, manufacturers of these chemicals do not need to notify their customers that these are reportable TRI chemicals.</div></b><div style="visibility:hidden"></div></b>-
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