You may be aware of our guidance document that we developed to provide compliance assistance with the TRI lead rule. It's available from our website. In that guidance we provide example calculations that pertain to many different industrial scenarios. These example calculations illustrate how facilities can make reasonable estimates regarding determinations as to whether they have tripped the 100 pound reporting threshold for lead and, if so, how to estimate releases of lead to the environment.

On page 5-5 of the document we provide an example that pertains to an electronic component manufacturing facility. In this example the facility performs wave soldering operations, and the facility has to determine whether they have tripped the 100 pound reporting threshold and estimate releases. From your e-mails it appears that this example addresses many of the questions that you've raised in your e-mail messages. In the example we provide an emission factor for lead emissions during wave soldering operations. The emission factor is 86 mg/hour: meaning that for every wave soldering line in a facility, 86 mg of lead is emitted to air each hour of the wave soldering operation. By knowing how many wave soldering units you have in your facility, and how many hours per year the wave soldering units are in operation, you can make a reasonable estimate of how much lead is emitted to air using this emission factor.

I wish to point out to you that the very first thing you need to do is determine whether you have even tripped the 100 pound reporting thresholds for processing, otherwise using or manufacturing lead at you facility. I have found from speaking with individuals from facilities that perform wave soldering operations, that many of them don't exceed the 100 pound processing threshold for lead, and, therefore, don't need to file a form R release report for lead with EPA (Assuming of course they do not exceed the 100 pound thresholds for manufacturing or otherwise use reporting thresholds for lead. See the lead guidance document for additional details or call me.).

During the wave soldering operation, in which you are applying solder to printed circuit boards, the only lead that you are processing is the lead that is being applied to printed circuit board (assuming that you are not processing lead anywhere else in your facility). The only caveat here is that for the first year of reporting under the new 100 pound reporting threshold, facilities should have considered all the weight of the lead (not the weight of the solder) that is in their wave soldering units towards the 100 pound processing threshold. In subsequent years (i.e.,, the current reporting year and thereafter) the only quantity of lead in their wave soldering units they need to consider towards the 100 pound reporting threshold is the quantity of lead (not the quantity of solder) they add to the wave soldering pot(s) during the course of the calendar year.

Let's assume that in the calendar year of 2001 a facility had only a single wave soldering unit within the facility and that this unit contained 240 pounds of solder that is 50% lead. Thus the facility processed 120 pounds of lead in calendar year 2001 (let's assume that the facility does not process lead anywhere else in the facility.) Clearly, the facility exceeded the 100-pound reporting threshold for processing lead, and therefore should have determined their total releases of lead from their facility during 2001, and file a form R release report by July 1, 2002. Let's assume that during the course of calendar year 2001 40 pounds of the solder (i.e., 20 pounds of lead) was removed from the wave soldering unit during the wave soldering operation and applied to printed circuit boards. Thus, in calendar year 2002, the facility must add 40 pounds of solder (i.e., 20 pounds of lead) to the wave soldering unit to replace the solder that was lost through application during 2001. When the facility gets around to determining whether they have exceeded the 100-pound reporting threshold for processing lead for calendar year 2002, they only need to consider the 20 pounds of lead that was added to the wave soldering unit. Of course, if lead was processed anywhere else in the facility during the course of 2002, this quantity of lead would need to be added to the 20 pounds and applied towards the 100 pound threshold for processing lead. If the 100-pound threshold for processing lead is not exceeded, there is no requirement for the facility to submit a form R release report. (For this example I'm assuming that the other thresholds (e.g., the 100 lb manufacturing threshold or the 100 lb otherwise use threshold) for lead are not exceeded).

Again, I would prefer to discuss this with you over the phone because in order for me to give you the best guidance I can I need to get more details as to what goes on inside your facility. What I've tried to do here is give you some general guidance that is geared specifically towards your facility and the concerns you've raised in your e-mail.

I hope this helps you. If not, please give me a call.

Sincerely,

Steve DeVito