A facility processes 24,000 pounds of nickel contained in stainless steel resulting in scrap metal containing 2,000 pounds of nickel that is sent off site for recycling. None of the scrap metal is returned to the facility. For purposes of TRI reporting, transferring TRI toxic chemicals off site for recycling is considered processing. Would the facility count both the 24,000 pounds and the 2,000 pounds of nickel toward the processing threshold?
Quantities of a listed toxic chemical undergoing multiple activities on site within a single activity threshold are counted only once during the activity sequence. In this scenario, the facility would not double count the nickel processed on site and, subsequently, prepared for off-site recycling. Therefore, the facility would only count 24,000 pounds toward the processing threshold and would not exceed the 25,000 pound processing threshold. However, if the recycled scrap metal was returned to the facility and the facility prepares the material for distribution in commerce, then the facility would count that quantity towards the processing threshold as well.