Question # 183

183. For Section 313 reporting requirements and threshold determinations, if a covered facility uses lead, lead chromate, and other chromium compounds, can they be considered separately or must they be combined into categories? When reporting releases and other waste management activities, must quantities of categories be determined as well?
Threshold determinations for metal containing compounds are made separately from parent-metal threshold determinations because they are listed separately under Section 313. In the scenario presented in the question, the facility would apply the quantity of the lead metal manufactured, processed, or otherwise used to the appropriate threshold for lead. The facility would apply the quantities of the lead chromate manufactured, processed, or otherwise used to the appropriate threshold for lead compounds and would apply the quantities of the lead chromate and other chromium compounds manufactured, processed, or otherwise used to the appropriate threshold for chromium compounds. However, a facility may, once a threshold has been met individually, combine the parent metal and its metal compounds for reporting. In completing the Form R, only the weight of the parent metal (not the entire compound weight) is to be considered.