Understand that I'm not an expert at EPA regs, but I have a guy who works for that much better versed in environmental regs.
He's working on the TRI report right now and just had a conversation with an EPA person about repoting on our brass.
THe guy who did the report in the past broke the brass into percentages of zinc and copper for reporting.

I've been reading the FAQ and can't really figure out what they want.

We machine brass. It creates chips, not dust. We don't melt it.
The copper and zinc are never liberated from the alloy.

so why would we have to report the copper as a separate chemical?

Isn't that like saying if you have a lot of salt you have to report chlorine and sodium?

Understand that I'm not an expert at EPA regs, but I have a guy who works for that much better versed in environmental regs.
He's working on the TRI report right now and just had a conversation with an EPA person about repoting on our brass.
THe guy who did the report in the past broke the brass into percentages of zinc and copper for reporting.

I've been reading the FAQ and can't really figure out what they want.

We machine brass. It creates chips, not dust. We don't melt it.
The copper and zinc are never liberated from the alloy.

so why would we have to report the copper as a separate chemical?

Isn't that like saying if you have a lot of salt you have to report chlorine and sodium?

I'm not an EPA expert either (I have no idea what a "TRI" is, e.g.) but it seems to be that the concern might be the liberation of those elements after the intact alloy leaves your building, as a matter of information for subsequent handlers. Traceability, in other words.

I'm not an EPA expert either (I have no idea what a "TRI" is, e.g.) but it seems to be that the concern might be the liberation of those elements after the intact alloy leaves your building, as a matter of information for subsequent handlers. Traceability, in other words.


TRI is Toxics Release Inventory.
http://www.epa.gov/tri/whatis.htm

It's meant as public information so people can be aware of hazards in their areas.

The chips and scrap are defined as emissions and they are required to be reported on the Form R...oh yeah, you better have it submitted by July 1 or else. No if's, ands or buts

I've had to do this myself many times in the past and I also thought it was a load of krap...we didn't "emit" anything.

The guidance document is pretty clear in what you have to do, but here is my basic approach.

I would take the total weight of all the "like" scrap that went to the recycler and divide it by the percentages (or the average of percentages in the case of multiple suppliers) of the materials listed in the msds. Let's say Stainless Steel had 10-13% chromium, I'd use the 13%. If we used 2 different Stainless Steels of which (1) had 10-13% chromium and the other had 15-18% chromium I would add the 2 high figures and divide by 2 (13+18=31, 31/2=15.5%) Then I would divide the total weight of the scrap by the % and submit that number on my report. Perfectly valid and acceptable...Just go to Evirofacts (the EPA site) and look under "Air Systems - Fort Smith, Arkansas" and you'll see what I submitted for 2003, 2004 and 2005.

It's a pain, but there are no options.

Remember, you only need to submit information that is at the reportable level and above.

The chips and scrap are defined as emissions and they are required to be reported on the Form R...oh yeah, you better have it submitted by July 1 or else. No if's, ands or buts

I've had to do this myself many times in the past and I also thought it was a load of krap...we didn't "emit" anything.

The guidance document is pretty clear in what you have to do, but here is my basic approach.

I would take the total weight of all the "like" scrap that went to the recycler and divide it by the percentages (or the average of percentages in the case of multiple suppliers) of the materials listed in the msds. Let's say Stainless Steel had 10-13% chromium, I'd use the 13%. If we used 2 different Stainless Steels of which (1) had 10-13% chromium and the other had 15-18% chromium I would add the 2 high figures and divide by 2 (13+18=31, 31/2=15.5%) Then I would divide the total weight of the scrap by the % and submit that number on my report. Perfectly valid and acceptable...Just go to Evirofacts (the EPA site) and look under "Air Systems - Fort Smith, Arkansas" and you'll see what I submitted for 2003, 2004 and 2005.

It's a pain, but there are no options.

Remember, you only need to submit information that is at the reportable level and above.

well - I guess the fortunate part is that while we have to report it, it's 100% accounted for as either recycled scrap or finished goods. No fugitive emissions or pits of buried treasure. So it all shows up as zeros on the database when I searched our ZIP code.

We only need to report for brass. Our stainless steel usage is below reportable limits.

Still - it seems silly.

Yeah, I know. Cutting and grinding does not break down material to their elemental state, but the EPA folks need to stay employed.

There are lots of good examples in EPA's EPCRA Section 313 Questions and Answers and Addendum.
For example:

355. I am a power tool manufacturer and we use copper, a listed toxic
chemical. We receive copper plates and shave the rough edges off them.
All of the shavings are vacuumed and sold to a scrap metal facility which
makes ingots and sells them. Is the copper plate an article? How do I
consider the shavings?
Because all of the copper released from the plate is collected and reused, no
reportable release has occurred and the article exemption is maintained. If
the copper is disposed of, on the other hand, the plates lose the article status.

365. Does the article exemption apply to flat rolled sheet metals, if they
are used in operations which typically produce scrap but no release?
Assuming the scrap metal pieces are recognizable as the original piece, the
article exemption does apply to these metals if the forming process caused
0.5 pounds or less of releases of a listed toxic chemical from all like items or
the items retain the thickness of sheet metal in whole or in part. Once an
operation is performed on a metal that causes a release which is not recycled
and which exceeds 0.5 pounds for the reporting year (for example, from
operations such as heating, grinding, or welding), the article exemption no
longer applies and releases must be reported when listed chemicals in a sheet
metal are processed in quantities greater than 25,000 pounds.

There are lots of good examples in EPA's EPCRA Section 313 Questions and Answers and Addendum.


I just referenced this doc last Friday. Here's the link in case anyone else is interested:

http://www.epa.gov/tri/guide_docs/1998/1998qa.pdf

Warning: It's big - 306 pages, about 3.7 MB on my hard drive (web site states 4.3 MB)

The document is linked through here (http://www.epa.gov/tri/guide_docs/index.htm#qa) with other TRI guidance documents.