Ask the Expert Question-and-Answer Archive (TRI)
by Joelie Zak, Scientific Control Labs, Inc.
Lead Anodes in Hex Chrome Plating
Q. I am not manufacturing a lead compound that exceeds the threshold of 100 pounds but I did report lead in 2003 as otherwise used (auxillary or plating aid in the process which gives
electrons during the plating operation, in another words the hex-chrome +6
will gain 6 electron from the lead anodes to deposit on the parts as neutral
atoms during oxidation / reduction process). For this reason, I am reporting the lead anodes as otherwise
used in the process due to the new threshold of 100 pounds There is about 930 pounds of anodes in the plating tank.
You should be doing a lead compound report. USEPA interprets that
electroplating "coincidentally manufactures" metal compounds. Lead compounds
are coincidentally manufactured in plating, wastewater treatment. Most
chromium plating facilities are reporting as "lead compounds". You should be
checking "manufactured, as a byproduct" as well as "otherwise use."