NMFRC Fact Sheet: Final National Emission Standards for Hazardous Air
Pollutants (NESHAP) for Plating and Polishing Operations
On July 1, 2008 EPA published the National Emission Standards for Hazardous Air Pollutants for Plating and Polishing Operations. This new rule impacts many metal finishing operations (EPA estimates 2,900 facilities). It applies to facilities with plating, polishing or thermal spray processes that contain cadmium, nickel, lead, manganese and/or chromium. (The rule will not apply to chromium anodizing and electroplating, which are covered under a previous rule.)
With this rule EPA did not establish emission limits for plating and polishing operations as they did with chromium plating, but instead required plating and polishing facilities to follow management practices as the generally available control technology (GACT) standards. To meet the new regulation affected facilities have several choices including use of wetting agents/fume suppressants (WAFS), air pollution control devices or tank covers. Platers will also need to implement management practices that reduce the generation of airborne chemicals.
Existing facilities must submit an Initial Notification by October 29, 2008 and comply with the rule by July 1, 2010. New facilities must be in compliance at startup.
Which processes are affected?
The regulation applies to any plating or polishing operation that contains elemental metal or compounds of cadmium, nickel, manganese, chromium and/or lead (elemental lead is excluded). The most common processes affected by this rule include:
- cadmium electroplating,
- nickel electroplating,
- lead electroplating,
- tin/lead electroplating,
- electroless nickel plating,
- chromate conversion coating,
- nickel acetate sealing,
- sodium dichromate sealing,
- manganese phosphating,
- mechanical polishing of metals, and
- thermal metal spraying.
The rule does not apply to the following:
- process that are subject to the Chromium MACT standard (40 CFR part 63, subpart N);
- processes that use cadmium, chromium, lead, and nickel in concentrations of less than 0.1% by weight and manganese in concentrations of less than 1.0% by weight;
- processes that use metals other than cadmium, chromium, lead, manganese, and nickel;
- tanks used strictly for educational purposes;
- thermal spraying processes to repair surfaces; and
- dry mechanical polishing on a surface prior to plating.
What emissions control methods is EPA requiring?
The Plating and Polishing NESHAP allows facilities to meet the standards using different approaches, as summarized below.
Non-cyanide plating and polishing tanks -- options include:
- use a wetting agent/fume suppressant (WAFS),
- capture and control emissions using an emission control device, or
- use a tank cover.
To meet the requirement for WAFS, the shop must use a bath chemistry that includes a WAFS or must add WAFS separately to the bath. In either case, the shop will be required to maintain the level of WAFS in the tank according to manufacturer’s specifications and requirements.
To meet the control device option, the shop must install, operate, and maintain a control system that includes a capture device designed to capture the plating and polishing metal HAP emissions from the tank and to transport the metal HAP emissions to a composite mesh pad (CMP), packed bed scrubber (PBS), or mesh pad mist eliminator (MPME).
The tank cover option distinguishes between batch process tanks and continuous process tanks. For batch process tanks, the cover must enclose the entire surface area of the tank and must be in place during at least 95 percent of the process operating time; for continuous process tanks, the tank surface area must be covered at least 75 percent during all periods of process operation.
In addition you are required to implement, as practicable, the applicable management practices (see below).
Cyanide plating tanks -- shops must perform and record a one-time measurement of pH in the tank bath. In addition you are required to implement, as practicable, the applicable management practices (see below).
Thermal spray processes -- For any existing thermal spraying processes, the rule requires a control system that is designed to capture metal emissions and transport them to a water curtain, fabric filter, or high efficiency particulate air (HEPA) filter. New thermal spraying operations are limited to use of a fabric filter or HEPA filter.
What are the applicable management practices?
All new and existing affected plating and polishing processes performed in tanks, regardless of bath pH, presence of cyanide, or use of electricity, would be required to comply with the following management and pollution prevention practices:
- minimize bath agitation when removing tank objects;
- maximize dripping of bath solution back into tank by extending drip time when removing the tank objects and using drain boards (i.e., drip shields);
- optimize the design of barrels, racks, and parts to minimize dragout of bath solution,;
- use tank covers, if available on-site at the facility, whenever possible;
- minimize or reduce heating during tank operation and when tanks are not in use, and
- perform regular repair, maintenance, and preventative maintenance of racks, barrels and similar equipment.
What are the initial compliance requirements?
To meet initial compliance requirements, the rule does not require any testing or monitoring to demonstrate compliance. Rather, shops must certify that they have implemented the specified management practices and/or controls systems as discussed above.
What are the continuous compliance requirements?
The rule requires owners or operators of all affected plating and polishing process tanks to demonstrate continuous compliance by adhering to the management and pollution prevention practices specified in this proposed rule, and by maintaining the appropriate records to document their compliance.
What are the notification, recordkeeping, and reporting requirements?
The rule specifies the following notification, recordkeeping and reporting requirements:
- Submit an Initial Notification by Oct. 29, 2008.
- Submit a Notification of Compliance Status by July 1, 2010 for existing processes, or at startup for new processes.
- Submit an annual compliance certification and, if there were any deviations during the year, a report that describes the deviations and the corrective action taken.
- Maintain all records that demonstrate initial and continuous compliance with this proposed rule, including records of all required notifications and reports, with supporting documentation; and records showing compliance with the management and pollution. Examples include:
- amount and frequency of WAFS additions,
- daily plating time; the time the tank is operated with a cover in place, and
- maintenance of any required control systems.
For most shops notifications and certifications will be submitted to your state environmental agency. If your state does not have the authority to administer this rule, then notifications and certifications must be submitted to your Regional EPA office.
What is due by October 29, 2008?
The rule specifies that you must submit an Initial Notification by Oct. 29, 2008. EPA will publish a form shortly that can be used for this purpose. An example of a notification form can be downloaded here.
EPA Fact Sheet.