MDI Emissions Reporting Guidelines for the ... - Polyurethanes

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Disposal and Treatment MDI Emissions Reporting Guidelines for the Polyurethanes Industry Activities that involve the disposal and/or treatment of an EPCRA Section 313 (TRI) chemical on-site or off-site are required by EPA to be reported. These activities are (but are not limited to): Discharges to surface waters Releases to land Releases to injection wells Surface impoundment On-site waste treatment, energy recovery, recycling Discharges to POTW Off-site waste disposal Transfer for energy recovery Discharges to receiving streams or water bodies are usually accountable in the facility’s NPDES permit. The permit lists the reported chemicals with limits on the quantity that can be discharged. Regulations require testing for amount of chemicals being discharged. You are also required to report releases contributed to storm water run-off. On-site releases to land are accountable under histories and spill records. EPCRA Section 313 (TRI) chemicals sent to off-site RCRA landfills must be reported according to EPA. Hazardous waste manifests contain description of waste and list waste composition that will aid you in calculating amount of EPCRA Section 313 (TRI) chemical being disposed. Facilities that use surface impoundment as a disposal method keep records of waste stream composition. This can be used in determining the percentage of volatile chemicals that will be evaporated. This release determination will be reported under fugitive emissions. Releases of EPCRA Section 313 (TRI) chemicals that are discharged into publicly owned treatment works (POTWs) must be reported to EPA. If totals are less than a 1,000 pounds, you may report that amount using a range, but if the quantity exceeds 1,000 pounds than you must report the exact estimate. Bases for determining the amount of EPCRA Section 313 (TRI) chemical discharged is usually based upon stream analyses and monitoring data that is required by permit. Transfers to off-site locations for the purposes of disposal, treatment, energy recovery or recycling must be reported. Estimates of quantities for these purposes are based upon chemical content contained in the overall waste. Materials that are shipped off-site for these purposes must be manifested. The manifest requires the listing of the chemical content. Analyses usually specify a range and judgment should be used in determining the amount. Transfers may also include any material that may include residuals in bags, totes, drums, tank trucks, and wasted product. 4-17
MDI Emissions Reporting Guidelines for the Polyurethanes Industry Estimates of residual content can range from 0 to 3% depending upon viscosity of the material. MDI is a solid while a mixture of MDI/PMDI is a liquid at room temperature. If you properly decontaminate the containers, in accordance with recommended procedure, before disposal, the amount of MDI and MDI/PMDI can be considered negligible. However, if you decontaminate containers you are required to report this as treatment and the amount of material treated and its treatment efficiency must also be reported. The bases for determining all releases fall into one of four categories: Monitoring data and direct measurement Mass balance Emission factors derived from scientific studies and are chemical, equipment, through-put, and chemical specific Engineering calculations using published mathematical formulas or best engineering judgment Use your judgment as to which method to use is critical. One has to weigh the validity of the data being presented along with the actual physical nature of the process and chemical to determine if the number calculated is correct. Over reporting or under reporting have serious consequences so think and use your personal judgment when determining releases. Stack Emissions (Point Source) Stack emissions are releases of EPCRA Section 313 (TRI) chemicals that are contained in confined air streams. Examples are emissions from stacks, vents, ducts, pipes and storage tanks. Emissions from pollution control equipment are also included in this category. In the following section we will be looking at various applications where MDI and MDI/PMDI mixtures are being used. Stack emissions will be calculated using sound engineering judgment. The applications where MDI and MDI/PMDI are used fall into the following three areas: 1. Enclosed Process (Cavity and Foam Density) 2. Open Process 3. Specialty Process 4-18
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