1998 EPCRA 313 Q&A, Question # 271

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.

Additional Details

Question # 271 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-271 Status Archived
Category 2. Exemptions Subcategory 2.B. Facility Maintenance and Structural Components
Keyword(s) Paint, Structural Component Exemption
Updated Q&A Question Number 353
Prior Q&A [Archived] Question Number 177, 1997 EPCRA 313 Q&A
Revision
History
Prior Source: [Archived] Question Number 177, 1997 EPCRA 313 Q&A: Structural Component Exemption-Paint. Type of Change: Minor - Minor edits are those edits which only involve non-substantive additions or deletions of words to provide clarity in the Question and Answer. Description of Substantive Edits: NA - NA indicates no substantive edits were made to the original Question and Answer.