Question # 474

474. A covered facility builds and repairs ships. During its welding operations, the facility uses a filler material to bind steel plates. This welding operation releases minor quantities of a toxic chemical. How are estimates of toxic chemical releases to be made?
If releases of the toxic chemical from the steel plate processing are recycled or reused or if the total amount released is 0.5 pound or less for the reporting year, then the releases are exempt from reporting under the article exemption. If the article exemption does not apply, the covered facility must include releases from the welding operation if thresholds are exceeded. EPA has developed tables to be used in estimating releases of metal in fumes for various types of welding and one for cutting mild steel. These tables can be found in Clarification and Guidance for the Metal Fabrication Industry (1998 version).