Applicability Determination Index

Determinations Specific to Electroplating

The general provisions of 40 CFR Parts 60 and 61 allow the regulated community to:

• request a determination of whether a rule applies to them (applicability determinations); or

• seek permission to use monitoring or record keeping which is different from the promulgated standards (alternative monitoring).

To ensure national consistency in implementing the regulations, EPA maintains a compilation of such letters and memoranda. In fact, EPA issues over 100 letters or memoranda per year on Clean Air Act (CAA) applicability or monitoring issues. These written responses are broadly termed "applicability determinations." EPA's repository for the correspondence is the Applicability Determination Index (ADI). The following are examples of published determinations relating to the metal finishing sector. Search the Applicability Determination Index at EPA.org to locate other applicable determinations.

Chromium Electroplating

• Does EPA approve alternative test methods alternative testing, monitoring, and work practice standards for Emission Elimination Device (EED) or Merlin cover?

• Are chromating tanks subject to Part 63, N, Chrome Plating?

• If a facility operates a tank to produce a protective conversion coating on magnesium parts using an anodic process without chromic acid, is the tank subject to the Chromium NESHAP?

• May a major source subject to the Halogenated Solvent MACT and the Chromium Electroplating MACT remove its halogenated solvent source after the compliance date for these standards, become an area source, and thus be exempted from Title V permitting?

• Will EPA require a facility to conduct another performance test for the hard chromium electroplating operation while operating a 12,000 amperage rectifier given that an initial performance test was conducted while operating a 6,000 amperage rectifier?

• Is the Thin Dense Chrome Plating process considered a hard or decorative chromium electroplating process?

• What is an acceptable alternative monitoring plan for a chrome plater using a Tri-mer Fan Separator and a dual-action fume suppressant?

• Are chrome strip tanks subject to the chromium electroplating and anodizing rule?

• Is a black electroplating tank considered a hard or decorative electroplating tank under the Chrome Plating NESHAP?

• Are black electroplating tanks considered hard or decorative electroplating under subpart N?

• Can rectifier capacity be de-rated in order to make a facility applicable to the small source category for Part 63 Subpart N?

• Does Sec. 63.342(e)(1) require facilities using trivalent chromium baths to use a premixed bath mixture containing the wetting agent?

• Does Subpart N cover continuous chromium electroplating of steel for products such as cans, and caps for bottles and jars?

• Are de-electroplating tanks subject to 40 CFR Part 63 Subpart N?

• Applicability of 40 CFR Part 63, Subpart WWWWWW (The Plating and Polishing MACT) to an etching process using chromic acid.

Solvent Cleaning

• Degreaser No Longer Using Regulated Solvent

• Application of Multiple MACT Standards to Sources

• Switching to non-HAP Solvent

• Airless/Airtight Degreasers

• Halogenated Solvent Cleaning Machine NESHAP

• Regulatory Status of Spent Solvents

• Calculating for Qualification for Solvent Exemption

• Classification of F003 Waste

• Solvents Covered Under F001 through F005 Listings

• Clarification of Paint Thinner

• Modifications to Alternative Monitoring Method