1998 EPCRA 313 Q&A, Question # 422

422. A covered facility has determined that it needs to report under EPCRA Section 313 for both elemental lead and lead compounds. Can this facility file one Form R that takes into account both the releases and other waste management activities of lead and lead compounds, or is it required to report separately?
If a covered facility exceeds thresholds for both the parent metal and compounds of that same metal, it is allowed to file one joint Form R (e.g., one report for both lead compounds and elemental lead). EPA allows this because the release and other waste management information reported in connection with metal compounds will be the total pounds of the parent metal released and otherwise managed as a waste.

Additional Details

Question # 422 Source EPCRA Section 313 Questions and Answers (Revised 1998 Version) (PDF)(306 pp, 3.4 MB, November 1998)
ID 98-422 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), Form R Submissions, Lead (Lead Compounds), Lead Compounds, Metal Compounds, Metals
Updated Q&A Question Number 515
Prior Q&A [Archived] Question Number 296, 1997 EPCRA 313 Q&A
Prior Source: [Archived] Question Number 296, 1997 EPCRA 313 Q&A: Form R-Form R Submissions; Lead; Lead Compounds; Metal Compounds; Metals. 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.