printreg,June,2004EPCRA Section 313 - Reporting Lead & Lead Compounds

printreg, June, 2004
EPCRA Section 313 - Reporting Lead & Lead Compounds


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From:Debra Jacobson(
djacobson@istc.illinois.edu)
Date:Tue, 22 Jun 2004 09:30:55
Just another reminder to review your inks and maintenance items for lead reporting on the EPCRA Section 313 reporting requirements. Reports are due July 1st!
Debra Jacobson

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In 2001, EPA classified lead and lead compounds as a PBT (persistent bioaccumulative toxic) chemicals. PBTs have much lower thresholds for reporting under SARA Title III Section 313. The threshold for manufacturing, processing, or using lead and lead compounds is 100 pounds. Because lead is a PBT chemical, a facility may not use the de minimis exemption, range reporting codes, or Form A.

PBT Chemical list: http://epa.gov/tri/chemical/pbt_chem_list.htm

At 40 CFR 372.28, EPA does allow an exception for lead contained in qualified alloys, which include stainless steel, brass, or bronze. Lead in stainless steel, brass, or bronze alloys remains subject to the higher non-PBT thresholds (25,000 lb. manufacture/process or 10,000 lb. otherwise use), so these alloys are not exempt from reporting for lead. A facility may use the de minimis exemption, range reporting codes, or Form A http://epa.gov/tri/report/Form_A_2003.pdf for the lead contained in qualified alloys.

40 CFR 372.28 http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=20c15da1f29f610c3fe37918b3744c67&rgn=div8&view=text&node=40:25.0.1.1.13.2.5.4&idno=40

For more information, including a guidance document on lead compounds, see http://epa.gov/tri/guide_docs/2001/lead_doc.pdf or http://epa.gov/tri/ . PBT thresholds are listed at http://epa.gov/tri/lawsandregs/pbt/pbtrule.htm.

Source: "reg of the day" listserv operated by Tammy Silverthorne @ the Environmental Resource Center



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