MDI Emissions Reporting Guidelines for the ... - Polyurethanes

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MDI Emissions Reporting Guidelines for the Polyurethanes Industry Introduction and Background The purpose of this document is to provide manufacturers, processors and other users of certain chemicals in the polyurethane industry with guidance on reporting releases of listed chemicals in accordance with the provisions of Section 313 of the Emergency Planning and Community Right-to- Know Act (EPCRA). In particular, this document outlines approaches for estimating emissions from the processing and use of 4,4'-methylene diphenyl diisocyanate (MDI) and mixtures of MDI and polymeric MDI (PMDI) in the absence of specific data on emissions. MDI and PMDI are EPCRA-listed chemicals in the “diisocyanates” category listing (N-120) for which reports must be filed. EPCRA Section 313 requires affected facilities to provide information on (1) routine and accidental releases of specific listed chemicals and mixtures of chemicals into the environment, (2) transfers to off-site facilities, and (3) waste treatment methods, and the efficiency of those methods. It also requires reporting on the name, location and type of business; the identity of the listed chemical(s) or chemical mixture(s) involved, and whether the chemical is manufactured, processed or otherwise used at the facility; and an estimate of the maximum amount of the chemical present at the facility at any time during the year. EPCRA-required information is reported on the Annual Toxic Chemical Release Form R. In certain circumstances, however, facilities may be able to report using the Toxic Chemical Release Form A, which requires significantly less information. Facilities are also required to comply with the provisions of the Pollution Prevention Act of 1990 (PPA). The PPA requires that source reduction and detailed information about on-site waste treatment and recycling be reported. Review definitions of “source reduction,” “treatment,” “recycling” and your activities, which are required to be reported accordingly. Reported information is placed in the Environmental Protection Agency's (EPA) Toxic Release Inventory (TRI) database, where it is made publicly available via the Internet and through the annual publication of the Toxic Release Inventory by EPA. 1-1
Use of TRI Database MDI Emissions Reporting Guidelines for the Polyurethanes Industry When Congress passed the EPCRA in 1986, EPA were mandated to promote contingency planning for chemical releases and provide the public with previously unavailable information about toxic and hazardous chemicals in their communities. Under Section 313(h) of EPCRA, Congress provides for the wide distribution of the industry information gathered. The release forms required under this section are intended to provide information to federal, state and local governments and the public. This includes citizens of communities surrounding the covered facilities. These forms provide information about chemical releases to the environment to enable government agencies, researchers, and other individuals conducting research and data gathering to develop appropriate regulations, guidelines, and standards. Since the TRI data has become available, it has become a useful resource for many different organizations: Federal, state and local governments use TRI data to set the priorities and allocate environmental protection resources. Regulators use TRI data to set permit limits, measure compliance with those limits, and target facilities for enforcement activities. Governments use TRI data to assess or modify taxes and fees based on toxic emissions or overall environmental performance. Communities use TRI data to begin dialogues with local facilities and to encourage them to reduce their emissions, develop pollution prevention plans, and address safety measures. Industry uses TRI data to identify pollution prevention opportunities, set goals for toxic chemical release reductions, and demonstrate its commitment to and progress in reducing emissions. Public interest groups use TRI data to identify the potential need for new environmental regulations or improved implementation and enforcement of existing regulations. Consultants and others use TRI data to identify business opportunities, such as marketing pollution prevention and control technologies to TRI reporting facilities. Therefore, it is important that reports be as accurate as possible. Overestimating emissions can lead regulators and others to seek imposition of controls that are not scientifically justified, while underestimating emissions can risk enforcement action by the Agency. 1-2
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