A TRI-covered facility welds two metal items together that independently meet the definition of an article as defined in 40 CFR §372.3. No releases occur from the joined metal items themselves, but there may be releases from the welding rods. Would the welding process negate the article status for the two metal items?
The article status of the metal items is not negated by the toxic chemical releases from the welding rods. The joined metal parts may be considered articles, and only the welding rods must be considered when making threshold determinations and releases and waste management calculations. However, if more than 0.5 pound of a toxic chemical is released from all like items, the item(s) would not qualify for the articles exemption.