Are the listed toxic chemicals contained in process-related equipment, such as piping, eligible for the structural component exemption?
No. If pipes are process-related, the structural component exemption does not apply and the facility may have to consider toward the facility's threshold determination amounts of listed toxic chemicals contained in process-related pipes that are put into use during the reporting year. The facility would also have to include release and other waste management amounts in calculations where applicable.
Additional information on the structural component exemption can be found in an FAQ titled 'Toxic chemicals in equipment used on site for several years' regarding on-site reuse of solid items or equipment (this would include process-related piping) and the Revised 1998 EPCRA Section 313 Questions and Answers Document.