1998 EPCRA 313 Q&A, Question # 276

276. Does the structural component exemption (40 CFR Section 372.38(c)(1)) cover the small amounts of abraded or corroded metals from pipes and other equipment that become part of process streams?
If the pipes are not process related, the structural component exemption would apply and the listed toxic chemicals contained in the pipes would not need to be considered in threshold determinations and release or other waste management calculations. If the pipes are process related, the structural component exemption does not apply, and if the facility exceeds a threshold for the listed toxic chemical, any releases and other waste management of the listed toxic chemical should be reported.

Additional Details

Question # 276 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-276 Status Archived
Category 2. Exemptions Subcategory 2.B. Facility Maintenance and Structural Components
Keyword(s) Pipes, Structural Component Exemption
Updated Q&A Question Number 359
Prior Q&A [Archived] Question Number 180, 1997 EPCRA 313 Q&A
Prior Source: [Archived] Question Number 180, 1997 EPCRA 313 Q&A: Structural Component Exemption-Pipes. 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.