271. A covered facility routinely paints the exterior of on-site buildings. The solvent in the paint is an EPCRA Section 313 toxic chemical. The paint brushes used to paint the buildings are cleaned with a solvent that is also an EPCRA Section 313 toxic chemical. Is the solvent used to clean the brushes subject to threshold determinations and release and other waste management calculations under Section 313?
The structural component exemption set out at 40 CFR Section 372.38(c)(1) applies to the solvent in the paint used to paint the facility. It also applies to the solvent used to clean the paint brushes since this is part of the painting process. Likewise, any paint and cleaning solvent residues would not be subject to threshold determinations and release and other waste management calculations.