MDI Emissions Reporting Guidelines for the ... - Polyurethanes

MDI Emissions Reporting Guidelines for the Polyurethanes Industry
Your purchases of Section 313 listed chemicals may serve as a benchmark in determining what
amounts you manufacture, process, or “otherwise use”; however, it is the actual amount of a
substance that is manufactured, processed, or “otherwise used” in the reporting year that
determines your reporting status. For example, a facility that purchased 30,000 pounds of MDI, a
listed chemical, but processed only 24,000 pounds in the reporting year would not be required to
report. Alternatively, a facility that purchased and processed 20,000 pounds of MDI and processed an
additional 6,000 pounds from the previous year’s inventory, thereby processing a total of 26,000
pounds in one reporting year, would be required to report.
For chemicals like MDI and PMDI that are included in a category, the reporting threshold is based on
the sum of all of the chemicals in the category processed or used in the reporting year. Thus, EPA
requires reporters to count all of the isocyanates manufactured, processed or “otherwise used” in
the category in that reporting year in determining if a threshold is met.
If you have a mixture or trade name product that contains a toxic chemical, you must determine the
amount of the toxic chemical in the mixture and combine that amount to the total quantity of the
chemical processed or otherwise used at the facility in order to determine whether or not the
reporting threshold has been reached.
Otherwise using:
EXAMPLE
Mixture 1: 10,000 pounds Mixture 2: 12,000 pounds
Components: 50% water Components: 50% water
50% MDI 50% Isophorone diisocyanate
Conclusion: Exceeds the reporting threshold for the diisocyanates category. You used 5,000 lbs of MDI
and 6,000 lbs of Isophorone diisocyanate. Because the total amount of diisocyanates exceeds the
10,000 pound “otherwise used” threshold, you must file a TRI Report.
Are You Subject to State MDI Permit Reporting Obligations?
The estimation techniques in this book are directed primarily toward calculating emissions for the
purpose of Section 313 reporting but may be useful in providing MDI emission estimates for state
permitting purposes as well. State air permit officials may be particularly interested in MDI
emissions, because MDI is a listed hazardous air pollutant (HAP). You should refer to your state and
local regulations for more information.
2-5