Question # 203

203. An electroplating facility uses metal cyanide compounds in their electroplating operations. Are they processing or otherwise using those cyanide compounds? How do they determine whether they meet the threshold, and which threshold applies?
The parent metal is plated onto a substance electrochemically. The metal compounds are processed, and the cyanide compounds are processed because the metal cyanide is the source of the metal that is plated and subsequently distributed in commerce. Metal cyanides are reportable as both cyanide compounds and metal cyanides. The total compound weight is applied for threshold determinations for both categories.