143. A facility manufactures an aluminum dust that is captured in a bag house, the dust is put into a smelter, and then put back into the process where it is recast into ingots, and sold. How is the dust considered for purposes of determining thresholds and estimating releases and waste management activities?
The facility must count the amount of aluminum dust that is manufactured toward the manufacturing threshold. The amount of aluminum dust that is collected and recast into ingots and sold is incorporated into a product that is distributed in commerce. These amounts are considered to be processed and must be counted toward that processing threshold. The aluminum dust that is captured from the pollution control device and put back into the process is reported in Part II, Section 8.6 (Quantity Treated On Site) because the aluminum dust is converted to a non listed form of the chemical.