Question # 201

201. We manufacture and use copper wire. We also use copper compounds in various parts of our processes. The Section 313 list contains both copper and copper compounds. Should we combine these categories for our determination of thresholds and reporting? Do we report the release and other waste management of copper compounds as copper metal?
Copper and copper compounds are separate entries on the Section 313 list, and therefore threshold determinations should be made separately. Copper compounds are a listed category and will include the aggregate of all copper compounds (other than the free metal). For copper compounds, report releases and other waste management activities as copper (e.g., as the copper ion in wastewater), not as the total mass of copper compounds. If a facility exceeds thresholds for both the parent metal and compounds of the same metal, EPA allows the facility to file a combined report (e.g., one report for copper compounds and copper metal).