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Compliance Costs Would Be $116 Million For TRI Lead Threshold
Change, EPA Says. Daily Environment Report, August 31, 1999,
pp. A-7-8.

Lowering the threshold for reporting lead under the Toxic Release Inventory under the conditions of a proposed rule would cost industry around $116,250,000 during the first year of the program, EPA estimates. This estimate includes the costs of staff to become familiar with the new requirements, to complete the required Form R and recordkeeping, and to perform other related tasks. After these initial costs, the agency estimates that the cost to industry in following years would be about $60 million each year. EPA estimates that 15,043 facilities would be newly required to file Form R under the new reporting threshold for lead; nearly 6,000 of these facilities would have to participate in the program for the first time.

Nearly 200,000 facilities would need to analyze their operations to determine if they would be covered under the new regulations. The electronics and motor vehicle industries would be most significantly affected by the new rules. Bulk petroleum stations and the coal mining industry would also be significantly affected. The proposed rule would lower the reporting threshold for lead from 25,000 pounds annually and 10,000 pounds annually (for the production of lead and the use of lead, respectively) to 10 pounds each year. It would also do away with the de minimus exemptions for lead-containing mixtures that are a part of the existing rule.

Comments on the proposed rule should be submitted to: Document Control Office (7407), Office of Pollution Preventions and Toxics (OPPT), Environmental Protection Agency, 401 M St, SW, Washington DC 20460. They may also be sent via email to oppt.ncic@epamail.epa.gov. Comments should identify the docket number OPPTS-400140.


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