The NMCP requires annual mercury emissions reporting from thermal units only (point sources).
TRI defines a mercury compound as “any unique chemical substance that contains mercury as part of the chemical’s infrastructure.” TRI reporting calculates emissions from releases to air (fugitive and point sources), water discharges, land, transfers off site and other waste management activities. Under the US EPA Toxic Release Inventory Program (TRI), the threshold for facilities to report mercury (mercury compounds) is 10 lbs per calendar year.
TRI Reporting is Different Than NMCP Reporting The Annual Emissions Reporting (pdf) document describes the emissions reporting protocol and the NMCP Method 29 Source Test Guidelines (pdf) contains the Method 29 source test parameters. Mercury emissions are calculated for every thermal unit, which is not De Minimis, using the most recent NDEP-approved stack test emission factor with actual throughput (production) values for the year. The NDEP reviews the data submittals and aggregates the data into a spreadsheet report by July 1st, each year. Annual reports are received by the NDEP in the month of March, each year. Pursuant to NMCP regulations, facilities must report mercury emissions and the mercury co-product collected annually.
Reporting Nevada Mercury Control Program (NMCP) - Annual Emissions Reporting