1998 EPCRA 313 Q&A, Question # 496

496. 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.

Additional Details

Question # 496 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-496 Status Archived
Category 4. Completing the Form R: Releases and Waste Management Calculations Subcategory 4.A. Releases of the Toxic Chemical
Keyword(s) Byproduct (Coincidental Manufacturing), Chemical Conversion (Activity Threshold), Chemical Identity, Release Reporting, Releases (Released)
Updated Q&A Question Number 608
Prior Q&A [Archived] Question Number 359, 1997 EPCRA 313 Q&A
Prior Source: [Archived] Question Number 359, 1997 EPCRA 313 Q&A: Byproduct; Chemical Conversion; Chemical Identity; Releases-Release Reporting. Type of Change: Minor - Minor edits are those edits which only involve non-substantive additions or deletions of words to provide clarity in the Question and Answer. Description of Substantive Edits: NA - NA indicates no substantive edits were made to the original Question and Answer.