Lead Disposal

Q. I think I know the answer to this question from the class you taught me during AESF Week 2001, but I want your opinion anyway. We sold the lead liner from an old anodizing tank to a scrap metal dealer last year. The liner weighed about 1000 pounds. Does this action by itself trigger the submital of a TRI report?

A. This is a good question. Actually, if using the lead liner in the tank did not result any release of lead greater than a 0.5 lb. in 2002, then it is article exempt. You would need to demonstrate this by showing an analysis of your anodizing bath for lead and doing the appropriate threshold determination calculations. However, if other areas of your production trigger the lead threshold, the action of sending the liner out as scrap would be reported on the "recycled off-site" section of the Form R.