Report on the Corrosion of Certain Alloys

On August 22, 2001 (66 Federal Register 44107), EPA made available for comment a document titled "Report on the Corrosion of Certain Alloys." (Note: The comment period closed on December 20, 2001.) This document contains information on the corrosion of stainless steel, brass, and bronze alloys. The document discusses the major types of environmental conditions and how these environmental conditions can affect the corrosion resistance of the stainless steel, brass, and bronze alloys. The document focuses on the availability of chromium, nickel, and copper from stainless steel, brass, and bronze alloys as a result of corrosion under environmental conditions.

The reporting of chromium, nickel, copper, and other EPCRA section 313 listed toxic metals in alloys is currently required because the elemental metals are subject to reporting and the Agency considers alloys to be solid-solid mixtures. Therefore, the weight percent of any listed chemical in a mixture must be factored into threshold determinations and release and other waste management calculations.

In the early 1990s, EPA received several petitions to delist chromium, nickel, and copper when found in stainless steel, brass, and bronze (alloys that contain chromium, nickel, and copper) from the EPCRA section 313 list of toxic substances. The underlying basis of these petitions was that the petitioners believe that these metals, as they exist in these alloys, are not available and will not become available to exert their toxicity when released to the environment. These petitions were denied based on the Agency's determinations that: (1) chromium, copper, and nickel meet the criteria of EPCRA section 313(d)(2)(B) and (C); and (2) corrosion of certain forms (e.g., dusts, grindings, and shavings) of the alloys brass, bronze, and stainless steel can reasonably be anticipated to occur under some processing, use, or disposal situations yielding soluble forms of these constituent metals. The petitioners failed to provide, nor did the EPA possess, any data to support the petitioners' contention that manufacturing, processing, use, or other activities involving the metal alloys would not lead to availability of these metals.

In the notice denying these petitions, EPA solicited public comment on the reporting of chromium, nickel, and copper in stainless steel, brass, and bronze alloys. EPA specifically requested comment on whether the reporting of chromium, copper, and nickel in certain forms (e.g., blocks) of the alloys should be exempted from the reporting requirements of EPCRA section 313. EPA stated that depending upon the nature of the information submitted, EPA would consider proposing a qualification to the EPCRA section 313 listing to exempt from reporting those forms of an alloy for which data can be provided that indicate corrosion will not occur. In the comments received EPA did not receive sufficient information to propose any such qualifier. However, EPA has continued to review this issue to determine if an exemption qualifier for alloys is scientifically supportable. To this end the Agency directed a comprehensive review and analysis of available data pertaining largely to the stability and fate of stainless steel, brass, and bronze alloys in the environment, the availability of their constituent metals, and prepare a report that describes the results of this undertaking. The Agency had the report peer reviewed, and revised the report accordingly. The present document is the revised version of the report.

• Federal Register Notice (PDF) August 22, 2001, 66 Federal Register 44107 (3 pp, 40K, About PDF)
  
  
• Report on Corrosion of Alloys (PDF) (71 pp, 303KB, About PDF)
  

Note: Tables contained in the report are difficult to view in the PDF version. Rich-Text and Word Perfect 8 versions have also been posted for your convenience.