Ask the Expert Question-and-Answer Archive (TRI)

by Joelie Zak, Scientific Control Labs, Inc.
July, 2002

Mercury From Plating Operations

Q. Joelie - thanks for being an available expert. I am working on a project for WA state, dealing with mercury abatement/removal, etc. 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 actually report?

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 components).

I cant think of a single company that we do TRI reports for that reports for Hg.

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.