MDI Emissions Reporting Guidelines for the ... - Polyurethanes

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MDI Emissions Reporting Guidelines for the Polyurethanes Industry Are You Subject to EPCRA Reporting Obligations? This section of the booklet summarizes the general steps to determine if you must report releases of MDI, MDI and polymeric MDI mixtures and other EPCRA Section 313 (TRI) chemicals that you manufacture, process, or use. Is Your Facility Subject to Section 313 Reporting? EPCRA Section 313 (TRI) reporting requirements apply to facilities in specified North American Industry Classification System (NAICS) codes. The full list of codes is available at www.epa.gov/tri. These codes correspond to Standard Industrial Classification (SIC) Codes 20-39, among others, and include chemical manufacturers, coating manufacturers, plastic resin, foam, and other plastic product manufacturers, foundries, boat builders, and automotive and recreational vehicle manufacturers. Do You Manufacture, Process or Otherwise Use MDI, PMDI or Other Substances That Are On the Section 313 List? Both 4,4'-methylene diphenyl diisocyanate (4,4'-MDI or MDI) and polymeric MDI (PMDI) are included in the diisocyanate category. 4,4'-MDI is identified by Chemical Abstract Services (CAS) Registry Number (RN) 101-68-8 and should be aggregately reported with other isocyanates in Category N120. Synonyms for MDI are provided in Table 1. Table 1 Synonyms for MDI 1,1’-methylenebis [4-isocyanato benzene] 4,4’-diisocyanatodiphenylmethane bis(4-isocyanatophenyl) methane methylenebis(p-phenylene isocyanate) diphenylmethane 4,4’-diisocyanate methylenebis (p-phenyl isocyanate) methylenebis (4-isocyanatobenzene) bis (1,4-isocyanatophenyl) methane MBI methylenebis-p-phenylene diisocyanate 4,4’-MBI 4,4’-methylenediphenylene isocyanate isocyanic acid, methylenedi-p- phenylene ester 4,4’-diphenylmethane diisocyanate bis(p-isocyanatophenyl) methane p,p’-diphenylmethane diisocyanate p,p’-methylenebis (phenyl isocyanate) 4,4’-methylenedi-p-phenylene diisocyanate 4,4’-methylenebis (phenyl cyanate) diphenylmethane diisocyanate methylenebis (4-phenyl isocyanate) di(4-isocyanatophenyl) methane methylenedi-p-phenylene isocyanate 4,4’-methylenebis(isocyanatobenzene) 4,4’-diisocyanatodiphenylmethane methylenebisphenylene diisocyanate isocyanic acid, diphenylmethylene ester 2-1
MDI Emissions Reporting Guidelines for the Polyurethanes Industry The most widely used MDI/PMDI mixture consists of approximately 50% monomeric 4,4'-methylene diphenyl diisocyanate (MDI, CASRN 101-68-8) -- which was on the Section 313 list even before EPA promulgated the November 1994 rule - and 50% higher molecular weight oligomers (PMDI, CASRN 9016-87-9) of variable composition. 1 This MDI/PMDI mixture generally exists as an amber, viscous liquid at ambient temperatures. As described in the discussion above, MDI and PMDI are aggregated with other isocyanates for TRI reporting. Only a single cumulative quantity is reported using the diisocyanates Category Code N120. Please note that individual CAS Registry Numbers should NOT be used when reporting under Category Code N120 according to EPA. Users and processors are required by EPA to report releases of all chemicals in any listed category listing as a single number. Different estimation techniques will likely be needed for the various members of the diisocyanates category. This book provides guidance on MDI and PMDI only. Table 2 lists all the isocyanates in the category. Please note that TDI is not a member of the diisocyanates category, and that the 1 59 Fed. Reg. 61,432 (November 30, 1994). Table 2 Isocyanates in the EPCRA Section 313 Diisocyanates Reporting Category Category Code N120 Chemical Name CASRN Methylenebis (phenyl isocyanate) (MDI) 101-68-8 1,3-Bis(methylisocyanate)-cyclohexane 38661-72-2 1,4-bis(Methylisocyanate)cyclohexane 10347-54-3 1,4-Cyclohexane diisocyanate 2556-36-7 Diethyldiisocyanatobenzene 134190-37-7 4,4'-Diisocyanatodiphenyl ether 4128-73-8 2,4'-Diisocyanatodiphenyl sulfide 75790-87-3 3,3'-Dimethoxylbenzidine-4,4'-diisocyanate 91-93-0 3,3'-Dimethyl-4,4'-diphenylene diisocyanate 91-97-4 3,3'-Dimethyl diphenylmethane-4,4'-diisocyanate 139-25-3 Hexamethylene-1,6-diisocyanate 822-06-0 Isophorone diisocyanate 4098-71-9 4-Methyldiphenylmethane-3,4-diisocyanate 75790-84-0 1,1-Methylenebis(4-isocyanatocyclohexane) 5124-30-1 1,5-Naphtalene diisocyanate 3173-72-6 1,3-Phenylene diisocyanate 123-61-5 1,4-Phenylene diisocyanate 104-49-4 Polymeric diphenylmethane diisocyanate (PMDI) 9016-87-9 2,2,4-Trimethylhexamethylene diisocyanate 16938-22-0 2,4,4-Trimethylhexamethylene diisocyanate 15646-96-5 2-2
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700 2nd Street NE • Washington, D
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