We have implemented TRI reporting based on the new regulation.
We had waste water testing -- lead is always below detection limit.
 An independent firm was hired to test the emissions from our exhaust stacks
-- also below detection limits -- and provide a certification report.
Beyond this we use mass balance to figure lead disposition.

I recommend you start preparing for this report.
Regards,
Brad Vanderhoof


 -----Original Message-----
From: Stephen R. Gregory [mailto:[log in to unmask]]
Sent: Tuesday, June 19, 2001 4:45 PM
To: [log in to unmask]
Subject: [TN] TRI reporting...



Hey all ya'll!

This is a topic that was brought up earlier by Dave Fish I believe, it has
to
do with the latest EPA mandate about TRI (Toxic Release Inventory) of which
lead is a one of the materials listed...

The cut-off is 100-lbs, which means if you use less than 100-lbs, you are
not
required to report anything. Most of us go through 100-lbs. without thinking

about it, so I guess I'm repeating Daves question; "Has anybody thought
about
this regulation?", how it's going to affect them?...and what needs to be
done
to comply?

According to what I've read so far, the TRI lead rule lowers the reporting
thresholds for lead and lead compounds to 100 pounds because lead and lead
compounds are what the EPA terms as persistent bioaccumulative toxic (PBT)
chemicals. Facilities that manufacture, process, or otherwise use more than
100 pounds of lead or lead compounds must submit a TRI Form R. The first
reports under the new rule must be submitted by July 1, 2002 for the 2001
reporting year.

Is anybody on this fine group looking at this? Just curious...


-Steve Gregory-

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