Ask the Expert Question-and-Answer Archive (TRI)
by Joelie Zak, Scientific Control Labs, Inc.
Mercury From Plating Operations
Q. Joelie - thanks for being an available expert.
I am working on a project for WA state, dealing with mercury
We have a number of plate / fabricators in the state that reported mercury
releases under TRI. do you know the potential sources? (for blueing,
coloring, electroplating??) and, do you know if any of these mercury-based
processes are being phased out in general.
Secondly, it seems that there are MANY WA companies that should have
reported under TRI that didnt. Do you know how reliable the TRI system is?
e.g., would you guess that all generators of hg in more than 10 pounds
A. I can only respond from the electroplating and other metal
finishing/fabricating perspective and that is that the only mercury that
would be found in these types of operations would be from broken switches,
thermometers and light bulbs/ballasts. These are the most likely sources,
but usually not subject to TRI reporting if they are intact (i.e., "article
I cant think of a single company that we do TRI reports for that reports
Regarding companies not filing Form R: Overall, the TRI threshold
determination system is very confusing and subject to a lot of
interpretation. In the recent years, EPA has been doing enforcement that has
clarified this process, but many companies are still confused about
determining when they have to report.