For Toxics Release Inventory (TRI) reporting under EPCRA Section 313, is on-site conversion of a metal compound to an elemental metal or from the elemental form of a metal to a compound of that same metal considered treatment for destruction?
Generally, if the conversion of a listed TRI toxic chemical into another substance (listed or not) takes place in a wastestream, it is considered treatment for destruction of the initial chemical. Metals, however, generally are not considered as treated for destruction because only the weight of the parent metal is reported and the parent metal cannot be destroyed. Therefore, the conversion of an elemental metal to a compound of the same metal or from a metal compound to the elemental form of the same metal is not considered treatment for destruction, even when such conversion takes place in a wastestream. There are, however, a few instances in which a TRI metal or metal category compound may be considered treated for destruction upon its conversion to another form or substance because the newly formed substance is not a listed TRI chemical. For example, when elemental barium or a barium compound is converted to barium sulfate in a wastestream, this is reported as treatment for destruction because barium sulfate is not a listed TRI chemical. Similarly, aluminum and zinc, which are only reportable in the form of fumes or dusts, are considered treated for destruction when they are converted into non-reportable forms if this conversion takes place in a wastestream. Additional information regarding treatment for destruction can be found in the Waste Management Activities: Recycling, Combustion for Energy Recovery, Treatment for Destruction, Waste Stabilization and Release document on the TRI Guidance Web site.