From: Curt Schmidt(Curt.C.Schmidt@westgroup.com)
Date: Tue, 7 May 2002 08:29:35
Regarding the haz waste question: If it is being recycled you can claim that the lead is excluded from being a solid waste under the scrap metal exclusion in 261.4(a)(13). But I would check with the local haz waste authority first; interpretations can vary.
Regarding SARA 313: That's more tricky and depends on several things; you can claim exemption if the lead meets the "article exemption." Because of all the confusion with the new lead rule, EPA created a pretty big "guidance document"; EPA Publication 260-B-01-027 (December 2001) which can be viewed or downloaded at http://www.epa.gov/triinter/guide_docs/2001/lead_doc.pdf. Section 2.1.2 defines the criteria that you need to meet for that exemption. Also Appendix B, Part 1 gives several decent Questions and Answers that may help clarify. Alternatively you can try the EPA EPCRA Hotline (see http://www.epa.gov/epaoswer/hotline/) or a comparable state EPCRA number. They might be able to provide guidance over the phone.
My opinions only. Good Luck