Contributor: Maria Race, CHMM Business Title: Regional Environmental and Safety Manager Contact Information: Clariant Corporation 1515 Miller Parkway McHenry, IL 60050 Phone: 815 363 0025 Fax: 815 363 0065 Email: maria.race@clariant.com Affiliation: Clariant Corporation is an international chemical company based in Switzerland with several divisions, including Masterbatch, which manufactures plastic color concentrate. Biography: Maria Race manages environmental health and safety for three U.S. sites associated with Masterbatch, a division of Clariant Corporation. Ms. Race has BS in Physics, University of Illinois at Urbana-Champaign, and an MS Environmental Technology, New York Institute of Technology.

Title of Presentation: Toxics Release Inventory New Lead Rule: What it Means for You Author: Maria Race Key Words: lead, TRI, SARA 313 Abstract: Objective - To present material regarding new lead reporting requirements under SARA 313, how they came into being, and how to approach compliance problems. Issues - Until this year, companies manufacturing or processing lead had a 25,000 pound thresholds (otherwise use was 10,000 pounds) before having to report SARA 313 emissions. Now, at a 100-pound threshold, many companies that were never before required to file TRI must file. Data collection for this begins immediately since the first reports will be based upon 2001 data. These reports will be due in 2002. Data gathering will be difficult because there is no accompanying requirement for companies to change their MSDSs. There is no deminimus level at which lead can be ignored for the purposes of calculating the 100 pounds, meaning that even a mixture that contains lead in under 1% could contain significant levels under TRI of lead when being ordered in 100,000 pound amounts. Many common materials, such as zinc compounds, contain lead in small quantities. Developments - EPA has developed guidance materials for compliance with this change in regulations. There is also a hotline available for questions. EPA has estimated that 38.3% of filers for lead will be new. Several commenting industries believe that this figure will be higher. Conclusions - Facilities with lead or lead compounds, even in materials where trace amounts are found, should evaluate their need to report under the current guidelines.