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Newest Rule affecting Plating Facilities
Permitting information
Quick Reference documents

**New Federal Rules Affecting Plating and Polishing Facilities**

The Environmental Protection Agency published new regulations on July 1, 2008, that impact plating and polishing facilities. The rule was issued to reduce vapors from facilities that contain cadmium, chromium, manganese, nickel, lead, and other harmful chemicals. It does NOT affect facilities that are subject to 40 CFR 63 Subpart N National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks.

What does the Rule Require?

• An Initial Notification

The regulations require affected sources to notify regulatory agencies that the rule applies to them. This notification requirement is referred to as an Initial Notification and must be submitted to the TN Division of Air Pollution Control by October 29, 2008. You must state that the Notification is submitted to meet the requirements of the Federal National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations 40 CFR 63 Subpart WWWWWW §63.11509(b) and 40 CFR 63 Subpart A, §63.9(b). A sample initial notification (REVISED 10/28/08) is available.

• A Notification of Compliance

Please note that existing facilities have until July 1, 2010 to actually comply with the rules' operating requirements. A Notification of Compliance Status must be submitted once a facility is in compliance with the rule, not later than July 1, 2010 for existing affected source. New affected sources (commenced construction/reconstruction after March 14, 2008) must comply with the rule, and submit both an Initial Notification and a Notification of Compliance Status upon startup.

When is the Initial Notification due?

Existing source initial notifications are due not later than October 29, 2008, or within 120 calendar days after your Plating and Polishing Facility becomes subject to the rule, whichever is later.

Who must respond and submit an Initial Notification?

This notification must be submitted by the owner or operator of a plating and polishing facility that:
• has emissions of less than 10 tons per year of any single hazardous air pollutant (HAP) or less than 25 tons per year of a combination of two or more HAPs.
• is engaged in one or more of the following processes:

Electroplating (Non-cyanide)
Continuous electroplating (noncyanide)
Short-term electroplating (noncyanide)
Electropolishing
Electroforming
Electroplating (cyanide)
Electroless nickel
Chrome conversion coating
Other electroless plating/coating/dipping
Thermal spraying (permanent line)
Thermal spraying (temporary, in-situ)
Dry mechanical polishing

Who is NOT required to submit the notification?

If your facility is
1. Subject to the requirements of 40 CFR part 63, subpart N (National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks).
2. A research and development process unit, as defined in § 63.11511 of the enclosed rule.
3. Process units that are used strictly for educational purposes.
4. Thermal spraying conducted to repair surfaces.
5. Dry mechanical polishing conducted to restore the original finish to a surface.
6. Any plating or polishing process that does not use any material that contains cadmium, chromium, lead, or nickel in amounts of 0.1 percent or more by weight, or that contains manganese in amounts of 1.0 percent or more by weight, as reported on the Material Safety Data Sheet for the material.

Letter explaining actions needed
 Sample intitial notification (REVISED 10/28/2008 ) (Note: Added process compliance information.You must provide if not previously submitted)
EPA Brochure on the Plating and Polishing Rule
Link to the complete rule for National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations 40 CFR 63 Subpart WWWWWW

Permits

Water Pollution
Electroplaters who discharge process water to a publicly owned treatment works (POTW) must obtain a permit from the operator of the POTW. A state NPDES Permit is required for discharge of process water to surface waters.  Manufacturers must also have a permit for storm water runoff.

Air Pollution
In Tennessee, air pollution is regulated in five geographical areas:
Davidson County
Hamilton County
Knox County
Shelby County
The other ninety one counties are regulated directly by state Air Pollution Control.

Polishing and buffing operations emitting particulates may require a permit from your air pollution control agency.  Other processes which produce gases and mists which require exhaust and scrubbers may also be regulated.  Boilers and other fuel burning operations may be regulated, depending on fuel used and size.

For a complete listing of all rule and implementation information, proposed and finalized, for chromium electroplating, the EPA has a comprehensive site for keeping abreast of any new changes.

40 CFR Part 63 Subpart N National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks applies to all platers who do these processes. The regulation requires specific control devices for hard chromium processes. The  NIST Hard Chrome Mist Suppressant Study  indicated that some chemical mist suppressants were effective in hard chromium baths.  An amendment to the 1994 regulation allows hard chromium platers to comply with the regulation by using mist suppressants and surface tension control.

Development of a new group of federal air pollution regulations for urban air toxics is under way. Plating and polishing are listed as source categories to be regulated  by these standards. 

Hazardous Waste
Electroplaters are usually classified as small quantity generators or large quantity generators of hazardous waste by the state Division of Solid and Hazardous Waste Management.  A permit is required for the treatment, storage, or disposal of hazardous waste from plating processes.

Quick Reference

For more information about Tennessee's Small Business Environmental Assistance Program, please contact the program at 1-800-734-3619 or by email at bgsbeap@state.tn.us