A covered facility processes aluminum and zinc. These two toxic chemicals are listed under Section 313 with the qualifier “fume or dust.” Is this processing operation subject to reporting?
If the processing of these substances generates (i.e., manufactures) any fume or dust or if the two substances were processed or otherwise used, at any time, as a fume or dust, the activities would be reportable under EPCRA Section 313. The manufacturing, processing, or otherwise use of these substances in fume or dust form would be subject to threshold determinations. Additional guidance on threshold determinations can be found in the Toxic Release Inventory Reporting Forms and Instructions and the Revised 1998 EPCRA Section 313 Questions and Answers Document.