186. A product is immersed into a plating bath containing nickel chloride (NiCl) to bond nickel to it prior to distribution in commerce. Nickel is incorporated into the final product whereas the chloride remains in the plating bath. Since nickel chloride is reportable under the nickel compound category of Section 313, which threshold applies?
The total weight of nickel chloride used in the plating bath is considered towards the facility’s processing threshold determination. If the facility exceeds the threshold, the owner/operator would only report releases and other waste management of the nickel, the parent metal. Because the facility is also creating elemental nickel, the amount of nickel manufactured from nickel chloride is considered towards the manufacturing threshold. The facility is also processing the elemental nickel. If the facility exceeds thresholds for both chemicals independently, they may file one Form R for nickel and nickel compounds.