Question # 516

516. A covered facility processes both elemental lead and lead compounds. The facility exceeds the 100 pounds per year processing threshold for lead compounds, but not for elemental lead, and must submit a report for lead compounds only. When calculating releases and other waste management activities from the lead compounds, the owner/operator is only required to account for the weight of the parent metal released (40 CFR Section 372.25(h)). Should the facility account for both releases of lead from activities involving lead compounds and releases of lead from activities involving elemental lead?
No. In the case when an activity threshold is exceeded only for lead compounds, the report is only required to be based on the releases and other waste management estimates of lead, the parent metal, from lead compounds only. Releases and other waste management estimates of lead resulting from activities involving elemental lead need not be included in the release and other waste management calculations. Conversely, if the facility were to exceed an activity threshold for only elemental lead, the report would only have to be based on releases and other waste management estimates from activities involving elemental lead only.