If a covered facility sends metal scraps containing chromium off-site to be remelted and subsequently reused, does it report the amount of toxic chemical in the metal as recycled off-site?
Assuming no contaminants are removed during the melting process, the chromium in the metal scraps is not actually being recovered but merely melted and reused. Therefore, the amount of the toxic chemical in the metal scraps would not be reportable in Part II, Sections 6.2 or 8 of the Form R. However, because the facility is repackaging and distributing the toxic chemicals in commerce, it should consider these amounts of the toxic chemical towards the facility's processing threshold. If the covered facility exceeds a chemical activity threshold, it is required to file a TRI Report for that chemical. Additional guidance on direct reuse can be found in the Revised 1998 EPCRA Section 313 Questions and Answers Document, an Information Center Monthly Report Question from March 2006, and the Toxic Release Inventory Reporting Forms and Instructions.