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printreg, May, 2002
Re: Lead Linotype


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From: Richard Illig (rillig@state.pa.us)
Date: Tue, 7 May 2002 07:44:57


Sherry,
0) The material may be hazardous as a waste but should also be recyclable.

1) You will need to check state regulations to see if stricter or additional requirements apply.

2) It may be possible to exempt the linotype under the definition of "waste", or as scrap metal, in 40CFR. (I doubt if this would be applicable based on information provided, but the generator should still explore the option.)

3) If not exempt as a "waste", the activity will probably be viewed as recycling. Recycling requires compliance with storage, manifesting, and transporter requirements (as best I am aware).

4) Since TRI requires reporting of both raw materials and wastes, I don't see how the generator could duck TRI unless they fall below the 100 pound per year threshold for lead. I would however watch out for, and clarify requirements about, potentially double reporting - counting the same material both as a raw material and a waste. I would be interested in hearing what you learn about TRI, or double reporting, from your example.



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