Questions and Answers

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  • 1 - 8 of 8
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Concentration Range; Facility; Mixture; SDS; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.C. Mixtures
<div style="visibility:hidden">19178 19-178 178 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.C. Mixtures Concentration Range; Facility; Mixture (Mixtures); SDS; Threshold Determination (Activity Threshold) 178. If a covered facility receives a Safety Data Sheet (SDS) from its supplier that states that the concentration of the TRI substance in the mixture ranges between zero and 10 percent, can the facility estimate the concentration of the TRI chemical in the mixture by using zero as the lower bound?No, a facility cannot estimate the concentration of a TRI chemical in a mixture by using zero as a lower bound concentration, even if the facility receives an SDS from a supplier stating that the concentration of a TRI substance is between zero and a stated upper bound. If an SDS shows zero as the lower bound of the concentration range, then the lower bound concentration is unknown, and the facility must use the provided upper bound for threshold determinations (40 CFR Section 372.30(b)(3)(ii)). Therefore, in the scenario above, since the facility only knows that the upper bound is 10 percent, it must calculate the amount of TRI chemical in the mixture based on the 10 percent concentration.</div></b><div style="visibility:hidden"></div></b>-
Mixture; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.C. Mixtures
<div style="visibility:hidden">19543 19-543 543 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.C. Mixtures Mixture (Mixtures); Threshold Determination (Activity Threshold) 543. A covered facility brings in natural and synthetic rubber in slab form. It then adds chemicals to the rubber to change it to what they are making (i.e., tennis balls). Does the facility need to consider the toxic chemicals in the rubber it receives?Yes. Rubber is a mixture for reporting purposes. Further, note that the weights of the non-PBT chemicals must be added to the threshold determination if their concentrations are above the de minimis concentration limit (1 percent, or 0.1 percent for OSHA carcinogens) while the weight of any PBT chemical must be added irrespective of concentration. The weight added would be the weight percent of the toxic chemical multiplied by the weight of the rubber slab. </div></b><div style="visibility:hidden"></div></b>-
Mixture; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.C. Mixtures
<div style="visibility:hidden">19546 19-546 546 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.C. Mixtures Mixture (Mixtures); Threshold Determination (Activity Threshold) 546. A facility has three separate process streams, one containing 2,4-toluene diisocyanate (TDI), with CAS number 584-84-9, the second containing 2,6-TDI, with CAS number 91-08-7, and the third containing TDI (mixed isomers) with CAS number 26471-62-5. How should a facility calculate the thresholds and releases for each isomer and for mixtures of TDI isomers? If the facility knows the composition of the mixture, should they total the amount of the pure 2,4-TDI and 2,6-TDI with the amount in the mixture to determine if the threshold for the individual isomers has been met?No. The Section 313 list of toxic chemicals includes listings for pure 2,4-TDI, pure 2,6-TDI and TDI (mixed isomers). The facility should calculate the thresholds separately for each process stream that contains the pure TDI isomers and the mixed TDI isomers. The individual TDI isomers of the mixed isomer process stream should not be applied to the thresholds of the pure isomers. If the individual thresholds for the pure TDI isomers are not met, no reporting is necessary. If the individual thresholds for the pure TDI isomers are exceeded, the facility may file a single report for TDI (mixed isomers) and include the total quantity released or otherwise managed as waste of all three process streams, or they may file three separate reports. If the thresholds for each TDI isomer in the mixed isomer process stream are not exceeded independently, but are exceeded collectively, the facility must report under the CAS number for TDI (mixed isomers). </div></b><div style="visibility:hidden"></div></b>-
Compound; Mixture3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.C. Mixtures
<div style="visibility:hidden">19560 19-560 560 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.C. Mixtures Compound (Compounds); Mixture (Mixtures) 560. What is the difference between a mixture and a compound?When a compound is formed, the identities of the reactant chemicals are lost, but in a mixture, the individual components retain their own identity and could be separated again. For example, since polyethylene is a reaction product, it is not a mixture for EPCRA section 313 purposes and is not subject to reporting. Steel fabricated into its solid form is considered a mixture because the individual metals retain their chemical identity.</div></b><div style="visibility:hidden"></div></b>-
Compound; Mixture; Release Reporting3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.C. Mixtures
<div style="visibility:hidden">19561 19-561 561 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.C. Mixtures Compound (Compounds); Mixture (Mixtures); Release Reporting 561. Must a facility report the various mixtures of compounds and substances that it manufactures?A facility must consider the specific compounds within mixtures, not the mixtures themselves, to determine whether a report must be filed. The individual listed chemicals or chemical compounds in mixtures are separately reported. </div></b><div style="visibility:hidden"></div></b>-
Best Available Information; CAS Number; Mixture3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.C. Mixtures
<div style="visibility:hidden">19562 19-562 562 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.C. Mixtures Best Available Information; CAS Number; Mixture (Mixtures) 562. When a company has a mixture on-site that does not have its own CAS number, what CAS number should be used?The company should use the best readily available information (e.g., SDSs, supplier notifications, and process and chemistry knowledge) at the facility to identify the listed Section 313 toxic chemicals in the mixture, in accordance with 40 CFR Section 372.30. A separate report must be filed for each toxic chemical for which the fraction of the toxic chemical in the mixture multiplied by the total weight of the mixture processed or otherwise used exceeds the applicable threshold. The toxic chemicals are treated as if they were present in pure form and each is reported under its own CAS number.</div></b><div style="visibility:hidden"></div></b>-
Mixture3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.C. Mixtures
<div style="visibility:hidden">19564 19-564 564 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.C. Mixtures Mixture (Mixtures) 564. When should the 'mixture component identity' field on the Form R be used?The 'mixture component identity' field is to be used only when a facility knows that a mixture it purchases and processes or otherwise uses contains a listed Section 313 toxic chemical but it does not know which toxic chemical (i.e., the supplier keeps the toxic chemical identity a trade secret). The facility must use the toxic chemical or the toxic chemical category name field in all other circumstances (unless it is declaring the toxic chemical a trade secret toxic chemical and is filling out a sanitized version of the form).</div></b><div style="visibility:hidden"></div></b>-
Metal Alloy; Mixture3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.C. Mixtures
<div style="visibility:hidden">19565 19-565 565 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.C. Mixtures Metal Alloy; Mixture (Mixtures) 565. How is galvanized sheet metal considered for EPCRA section 313 reporting? Are metals in alloys subject to Section 313 reporting?Galvanized sheet metal is an alloy of several different metals. An alloy is considered a mixture for Form R reporting because the individual metals in the alloy retain their chemical identities. Like all other listed toxic chemicals in mixtures, alloys are subject to Form R reporting. When determining whether a facility meets an activity threshold, the owner/operator should only consider the weight percent of the listed chemical in the alloy.</div></b><div style="visibility:hidden"></div></b>-
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