Question # 359

359. Does the structural component exemption (40 CFR Section 372.38(c)(1)) cover the small amounts of abraded or corroded metals from pipes and other equipment that become part of process streams?
If the pipes are not process-related, the structural component exemption would apply and the listed toxic chemicals contained in the pipes would not need to be considered in threshold determinations and release or other waste management calculations. If the pipes are process-related, the structural component exemption does not apply, and if the facility exceeds a threshold for the listed toxic chemical, any releases and other waste management of the listed toxic chemical should be reported.