Question # 512

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.