Lead Shots

Q. I have a client who uses lead shot (a free flow non graphite) and pours it into big castings and seals it. There is no waste from this process. They also use 5 pound ingots (plumbers lead) by melting it and filling castings then seal the castings. Currently they use over 100 lbs/year of both, but less than 10,000 lbs/year. Are they required to submit a TRI form?

A. Your client does need to do a Form R for Lead. They are subject to the 100 lb. threshold because they are "processing" the lead as an "article component". Under last year's rules, this would be subject to the 25,000 lbs. threshold. However, this use of lead is now subject to the 100 lbs. threshold.

You will now need to look at all sources of releases of lead from the facility, even if they aren't from either of these operations.