Questions and Answers

Each Q&A addresses a specific aspect of TRI reporting. There are a few options available to search the Q&As, which may be used individually or in combination:

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  • 1 - 5 of 5
Questions and AnswersKeyword(s)Category(hidden - contains search text)(hidden - contains search text)FedFac
Chemical Qualifier; Compound; Fume or Dust3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Fume or Dust
<div style="visibility:hidden">19257 19-257 257 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Fume or Dust Chemical Qualifier; Compound (Compounds); Fume or Dust 257. There are two chemicals on the list with the qualifier “fume or dust” (zinc and aluminum). What exactly is a “fume” or a “dust?”EPA does not have a regulatory definition of a fume or a dust, but considers dusts, for purposes of reporting, to consist of solid particles generated by any mechanical processing of materials including crushing, grinding, rapid impact, handling, detonation, and decrepitation of organic and inorganic materials such as rock, ore, and metal. Dusts do not tend to flocculate except under electrostatic forces. A fume is an airborne dispersion consisting of small solid particles created by condensation from the gaseous state, in distinction to a gas or vapor. Fumes arise from the heating of solids such as lead. The condensation is often accompanied by a chemical reaction, such as oxidation. Fumes flocculate and sometimes coalesce.</div></b><div style="visibility:hidden"></div></b>-
Aluminum; Coincidental Manufacturing; Compound; Fume or Dust; Process; Zinc3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Fume or Dust
<div style="visibility:hidden">19517 19-517 517 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Fume or Dust Aluminum; Coincidental Manufacturing (Byproduct; Coincidental Manufacture); Compound (Compounds); Fume or Dust; Process (Processing; Processed; Processes); Zinc 517. 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.</div></b><div style="visibility:hidden"></div></b>-
Aluminum; Chemical Qualifier; Compound; Fume or Dust3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Fume or Dust
<div style="visibility:hidden">19522 19-522 522 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Fume or Dust Aluminum; Chemical Qualifier; Compound (Compounds); Fume or Dust 522. A covered facility coats materials with aluminum using the vacuum deposition process. Is the facility subject to the reporting requirements under Section 313 for aluminum fume?No. In vacuum deposition, the aluminum is converted to the vapor state under low pressure. The vapor then condenses on the material that is being coated. A metal fume consists of finely divided particulate dispersed in a gas. Because a metal fume and a metal vapor are different physical forms of a metal, metal vapor is not considered to be a type of fume. However, any aluminum fume that is produced as a result of the condensation of the metal vapor should be applied to threshold determinations for aluminum. </div></b><div style="visibility:hidden"></div></b>-
Aluminum; Chemical Qualifier; Coincidental Manufacturing; Compound; Fume or Dust3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Fume or Dust
<div style="visibility:hidden">19523 19-523 523 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Fume or Dust Aluminum; Chemical Qualifier; Coincidental Manufacturing (Byproduct; Coincidental Manufacture); Compound (Compounds); Fume or Dust 523. A covered facility manufactures aluminum cookware. It generates aluminum dust of various particle sizes during polishing and edging of the cookware. The facility collects the larger particles of aluminum dust by wet cloth. Does the facility consider only smaller dust particles that escaped for reporting purposes?Aluminum in the form of dust is a listed Section 313 toxic chemical. All of the aluminum dust (no size limit) generated should be considered toward the manufacturing threshold. Provided the covered facility meets the activity threshold for aluminum fume or dust, the amount of the aluminum dust particles that escape the facility's collector system should be reported as released. </div></b><div style="visibility:hidden"></div></b>-
Compound; Fume or Dust; Mixture; Threshold Determination; Zinc3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Fume or Dust
<div style="visibility:hidden">19528 19-528 528 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Fume or Dust Compound (Compounds); Fume or Dust; Mixture (Mixtures); Threshold Determination (Activity Threshold); Zinc 528. A facility processes a zinc/mercury amalgam alloy and mercuric oxide to produce batteries. The amalgam is in particulate form. The molten amalgam is injected into a cooling chamber that produces particles with desired characteristics (such as size). Since zinc is listed as 'fume or dust' only, would the facility need to consider the zinc from the amalgam towards the applicable processing threshold?Yes. EPA considers 'dusts' to be solid particles generated by any mechanical processing of materials (including mixtures). This includes, but is not limited to, handling, crushing, grinding, and rapid impact of materials such as rock, ore, metals, and alloys. In this case, the particles produced would constitute a dust and require a threshold determination. </div></b><div style="visibility:hidden"></div></b>-
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