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.
June, 2002

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 years 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 arent from either of these operations.

 



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

NMFRC