NMFRC
 

NCMSCompliance Assistance Centers

Funded by EPA
through a Cooperative Agreement

EPA

Disclaimer
The information contained in this site is provided for your review and convenience. It is not intended to provide legal advice with respect to any federal, state, or local regulation. You should consult with legal counsel and appropriate authorities before interpreting any regulations or undertaking any specific course of action.

 

Ask the Expert Question-and-Answer Archive (TRI)

by Joelie Zak, Scientific Control Labs, Inc.
March, 2002

Carbon Steel and Lead

Q. Does the release of lead (0.5%)contained in carbon steel from cutting and welding operatioins at our facility fall under the 100 or 25,000 pound reporting criteria?

A. There is no longer a deminimus exemption for lead contained in carbon steel. The exemption to the 100 lb. threshold only applies to lead that incorporated into brass, bronze alloy and stainless steel.

Remember that in order to determine if you need to report, you first must do threshold determination calculations. For your facility, you would need to weld or cut more than 20,000 lbs. of carbon steel at 0.5% in the calendar year 2001 to exceed the 100 lb. threshold. Once this threshold is triggered, you need to report for lead and/or lead compounds.

The lead releases from the cutting and welding operations would need to be estimated or measured and reported under the "release" column on the Form R for Lead.

Thank you for your question. I hope this helps.



| Compliance Assistance | Regulations | Directories | Resources | Hot Topics | News | Ask the Experts | Library | Online Training | About NMFRC | Search | Home |

NMFRC