33 Days: Ambiguous SDS constituents, needs clarification example: Sulfuric acid, fuming sulfuric acid, and sulfur trioxide
Here’s an example of ambiguous constituent cleanup around sulfuric acid. You’ll see how you go back and forth between the sum of constituents by constituent name and the sum of receipts by SDS/CICN (Chemical Inventory Control Number) Number
Sulfuric acid may be at your facility in multiple products and in many different locations, including:
Bulk (55 gallon)
Laboratory reagent grade (typically 2.5lt or smaller containers)
Transfer containers in the lab and other locations sulfuric acid is used in testing/pH adjustment
Cooling tower treatment chemicals and test kit
Maintenance chemicals, including coil cleaner, drain cleaner, and general purpose cleaners
Food service cleaning chemicals
And possibly other locations, materials, and uses.
Remember that if you trip the Extremely Hazardous Substance EHS threshold determination value of 500 pounds for batteries (the most common source of Sulfuric Acid amounts greater than 500 pounds), you will need to report ALL of the materials that contain Sulfuric Acid, their locations, container types, hazard, and temperature and pressure on your Tier2 report.
(You may be able to exclude some of the materials if they are below 1 percent concentration, none of the above examples would qualify).
. Below are a few examples.. A few notes about these:
The Sulfuric Acid transfer container being poured into a beaker doesn’t appear to meet OSHA HazComm Transfer Container labeling requirements (unless being used by a technically qualified person on a single shift who doesn’t step away from their workstation). Consistently in top 10 of OSHA violations. We’ll do a “virtual March 2nd” post about this topic
Lebco Brute contains both Sulfuric Acid and Hydrofluoric Acid. Might be worth searching for a coil cleaner that works that has less hazardous ingredients
GreenClean is 35% Sulfuric Acid. Labels don’t necessarily tell you much about the hazards.
So now lets look at the data:
Go to the Constituent report we looked at yesterday, which is sorted by Constituent Synonym, then descengding by the Constituent Amount for each SDS, and which shows whether it’s a good CAS Number and what the CAS Number is (including the Text ones.
Most of the Sulfuric Acid battery entries are straightforward.
One note is that you may want to create a “dummy” SDS for Batteries that contains the EPA “rules of thumb”, for those batteries for which you don’t have a specific SDS/Specific manufacturer and model number. Remember those are
67% Lead (2/3)
33% battery acid (which would be an “ambiguous constituent” that doesn’t have a unique CAS Number associated with it
1/3 of 33% or 1/9 or 11% reportable Sulfuric Acid CAS 7664-93-9
But let’s take a closer look at the Fuming Sulfuric Acid constituents associated with SDS 7731:
The SDS has the usual and expected Sulfuric Acid constituent with a CAS Number of 7664-93-9 (above the oval MIXT WITH SULFERTRIOXIDE constituent)
It also has a Sulfur Trioxide constituent for SDS 7731, Sulfuric Acid Fuming, with a CAS Number of 7446-11-9
Interesting constituents for SDS 7731 Sulfuric Acid Fuming
Some examples of Sulfuric Acid and nearby entries on the EPA List of Lists
Comparing our SDS consituents with the EPA List of Lists for the Section 302 (EHS) TPQ column we find:
1 is the Sulfuric Acid we are familiar with, CAS 7664-93-8, with a Section 302/312 Threshold Planning Quantity TPQ of 1000 pounds. Since it is an Extremely Hazardous Substance EHS, we are required to report it on the Tier2 if the Maxiumum Amount on-site exceeds 500 pounds, or the TPQ, whichever is lower
2a includes Sulfuric Acid (fuming) and Sulfuric Acid, mixture with Sulfur Trioxide, both of which have a CS number of 8014-95-7. If you look on our constituent report above, you’ll see that CAS Number entered for SDS 7731. You’ll also see in the EPA List of Lists 2b that neither of these/that this CAS Number is NOT a Section 302 EHS with a TPQ. So when our Threshold determination by EHS runs, this CAS Number should not be included in the table it checks against as an EHS.
3a Sulfur trioxide IS listed in the Section 302 (EHS) TPQ column with 3b a TPQ of 100 pounds (lower than Sulfuric Acid). Let’s look at the constituents for SDS 7731
You’ll see that there are 3 constituents.
The combination constituent, Sulfuric Acid, Mixt with Sulfur trioxide with a CAS Number of 8014-95-7 is listed at 100% (the entire material is a combination of the two)
There was only a total of 2 pounds of this material in total (probably one 1-liter bottle)
The Sulfuric Acid constituent with CAS Number 7664-93-9 is listed at 80%. This is the CAS Number that matches the EHS list for Sulfuric Acid for Section 302 (TPQ) and will be used in Threshold determination calculations for Sulfuric Acid as an EHS
The Sulfur Trioxide constituent with CAS Number 7446-11-9 is listed at between a max of 1% and a min of 0%. This is the CAS Number that matches the EHS list for Sulfur Trioxide for Section 302 (TPQ) and will be used in Threshold determination calculations for Sulfur Trioxide as an EHS. If we exceeded thresholds for sulfur trioxide (unlikely in this case), could we exempt it? Maybe but I probably wouldn’t. We’'ll do a blog post on this special edge case when we get to Exemptions, Averaging, and other special cases (week 6 after we finish the first round of threshold determinations)
Clear as mud? reach out if I can help.
More tomorrow, here’s to March 2nd!
Community outreach: What other materials have you found to contain Sulfuric Acid at your facility and how were they used?
#SARA312 #SARATierII #SARATier2 #EPCRA #EGLE #March1EPAReportDeadline #ThresholdDeterminations #EHS #SulfuricAcid
Michigan Environment, Great Lakes, and Energy EGLE links from all three 2022 SARA 312 virtual training course webinars:
I’m reposting these links with my daily Tier2 post because they are so useful.
You can sign in and watch/listen even if you didn’t sign up for the webinar series.
RECORDING LINK FOR SESSION 2: Wed Jan 19, 2022.
Really good example on batteries. This is the “in the weeds” how to conduct your threshold determinations episode: https://attendee.gotowebinar.com/recording/4027906237723673347
I talked to Mike Young, one of the presenters, right after the first webinar. He said that it’s not unusual for them to take phone calls from people from other states (with the warning to confirm that your state doesn’t have differences in their requirements compared to Michigan).
RECORDING LINK FOR SESSION 1:
https://attendee.gotowebinar.com/recording/7957790593170499843
Michigan uses Tier2 Manager for report submission, which is a Michigan-specific program. If your state uses different software, you will need to review its specific requirements.
RECORDING LINK FOR SESSION 3:
https://attendee.gotowebinar.com/recording/2763075340284995085
If your state uses a different software program there may be some differences, but this webinar will probably also cover how to determine the Hazard Ratings, how to enter Locations, and other details associated with report submission. I’ll post the replay when it becomes available.
PRESENTATION: (I wasn’t able to attach a copy of the presentation, email the link below and they will send it to you)
SARA TITLE III – TIER II REPORTING WEBSITE: http://www.michigan.gov/sara
MICHIGAN FACILITIES’ GUIDE TO SARA TITLE III: https://www.michigan.gov/documents/deq/deq-oea-saraguidebook_509720_7.pdf
CONTACT INFORMATION:
Mike Young and Adam Pohl
517-284-7272
