608. Do the Section 313 reporting requirements overlook the possibility that a substance can lose its chemical identity as a byproduct in a reaction, and that the difference between “input and output” volumes may not always be due to a release?
EPA does recognize that a toxic chemical can lose its chemical identity in a reaction by being converted into a new chemical. The facility must still account for the amount they either manufacture or process regardless of whether the listed toxic chemical is converted to another toxic chemical in the process. Releases and other waste management estimates must then be calculated for any part of the process involving the Section 313 listed toxic chemical. In addition, if the byproduct created is a listed toxic chemical, the facility must consider it toward the manufacturing threshold.