New federal TRI reporting rule affects forms due from foundries July 1. (Washington Alert).

The U.S. EPA recently changed the rules for reporting under the Federal Toxic Release Inventory (TRI). If lead exists in any form in a facility (even as an impurity in metal melts), the foundry may need to file a report with EPA. This maybe true even if the foundry has not been required to file

Under the federal Emergency Planning and Right-to-Know Act, companies that use more than a certain minimum amount of any of nearly 200 toxic chemicals are required to submit a Till Form R directly to EPA by July 1 annually.

The threshold for most toxic chemicals, including lead and lead compounds, was previously set at 25,000 lb for chemicals "manufactured" or "processed" and at 10,000 lb for chemicals "otherwise used." Under the new lead rule, the threshold has been lowered to 100 lb of lead or lead compounds for each use category. The lead rule is retroactive to January 1, 2001, so TRI reports due this July must include data for all of 2001.

Because of this new rule, many foundries will be required to submit a Till Form R to EPA for the first time this year. One hundred pounds is a small fraction of a typical foundry's yearly production total, and small concentrations of lead in casting alloys (even trace impurities) can be significant for threshold calculations.

Typical maximum levels of lead present as impurities in casting alloys can range between 0.005-0.25%. In other words, a foundry can be melting an alloy that contains less than one tenth or a hundredth of the maximum concentration of lead allowed by the specification for that alloy and still exceed the lead threshold.

Foundries must complete this calculation for all the alloys melted at the facility and total those numbers together. If the total amount of lead melted is greater than 100 lb, the facility will need to submit a report. In addition to alloys melted, be sure to consider other potential sources of lead, including soldering operations, traces of lead in wastewater from lead cooling coils and other potential sources.

Additional information can be found on EPA's TRI website at http://www.epa.gov/tri/. For information specific to the new lead rule, visit http://www.epa.gov/tri/lawsandregs/lead/tri_pb_rule.htm.