1998 EPCRA 313 Q&A, Question # 417

417. We manufacture and use copper wire. We also use copper compounds in various parts of our processes. The Section 313 list contains both copper and copper compounds. Should we combine these categories for our determination of thresholds and reporting? Do we report the release and other waste management of copper compounds as copper metal?
Copper and copper compounds are separate entries on the Section 313 list, and therefore threshold determinations should be made separately. Copper compounds are a listed category and will include the aggregate of all copper compounds (other than the free metal). For copper compounds, report releases and other waste management activities as copper (e.g., as the copper ion in wastewater), not as the total mass of copper compounds. If a facility exceeds thresholds for both the parent metal and compounds of the same metal, EPA allows the facility to file a combined report (e.g., one report for copper compounds and copper metal).

Additional Details

Question # 417 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-417 Status Archived
Category 3. Determining Whether or Not to Report: Listed Toxic Chemicals Subcategory 3.B. Toxic Chemical-Specific Questions-Compound and Compound Categories
Keyword(s) Compound (Compounds), Copper Compounds, Metal Compounds, Threshold Determination (Activity Threshold)
Updated Q&A Question Number 201
Prior Q&A [Archived] Question Number 291, 1997 EPCRA 313 Q&A
Prior Source: [Archived] Question Number 291, 1997 EPCRA 313 Q&A: Copper Compounds; Metal Compounds; Threshold Determination. Type of Change: No Change to the Original - No Change to the Original indicates that either no change was made between the original Q"A and the 1998 version of the Q"A or that the only edits that were made involved punctuation changes. Description of Substantive Edits: NA - NA indicates no substantive edits were made to the original Question and Answer.