Question # 360

360. The structural component exemption under EPCRA section 313 covers the small amounts of abraded/corroded metals from pipes and other non-process related facility equipment (40 CFR Section 372.38 (c)(1)). Does the structural component exemption apply to equipment which regularly suffers abrasion, such as grinding wheels and metal working tools? What criteria can a facility use to decide which pieces of equipment are structural components and which are not?
The EPCRA section 313 structural components exemption would not apply to grinding wheels and metal working tools. These items are intended to wear down and to be replaced because of the nature of their use. The structural component exemption applies to passive, non-process related structures, such as pipes for potable water not related to the facility’s process. The abrasion/corrosion includes normal or natural degradation, such as occurs in pipes, but not active degradation, such as occurs in a grinding wheel.