Should release chemicals of interest (COI) presently in process or chemicals that are by-products be considered when determining the total On-site Quantity (TOQ)?
Yes, when determining the Total On-site Quantity for release-COI, a facility must also include COI that are present as process intermediates, by-products, and incidental production materials (see 6 CFR 27.203(b)(1)(ii). A facility should compute the TOQ using the same provisions a facility considers when determining whether it possesses a release-COI in an amount at or above the applicable STQ; therefore, release-COI in process and in by-products should be considered in both.
Related Questions
- Should release chemicals of interest (COI) presently in process or chemicals that are by-products be considered when determining the total On-site Quantity (TOQ)?
- What is included when determining whether a facility possesses an amount of a theft/diversion chemical of interest COI for theft/diversion chemicals?
- How do I calculate the Total On-site Quantity (TOQ) of COI in a mixture?
