Linn County Air Quality Division
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Plating and Polishing Operations



40 CFR Part 63, Subpart WWWWWW (NESHAP 6W)

FINAL RULE (eCFR | (PDF File)
General Requirements (DOC File)
Fact Sheet - All Processes (DOC File | PDF File)
Fact Sheet - Process Tanks (DOC File)
Fact Sheet - Thermal Spraying (DOC File)
Fact Sheet - Dry Mechanical Polishing (DOC File)

Initial Notification Form - July 1, 2010 (PDF File)
Notification of Compliance Status Form - July 1, 2010 (PDF File)

Brief Summary
New EPA Regulations for
Plating and Polishing Operations
40 CFR Part 63 Subpart WWWWWW

EPA has requirements to reduce air pollution from plating and polishing facilities. The vapors from these facilities contain cadmium (Cd), chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), and other harmful chemicals that pose a health risk to anyone who breathes in air containing them.

Below is a short summary of the requirements plating and polishing operations must comply with. For more details and assistance, please contact the Air Quality Branch.

Specific Requirements

  • Owners or operators of existing facilities must be in compliance with the rules by July 1, 2010. New sources must be in compliance before initiating operations. Existing facilities are defined as those constructed or most recently modified before March 14, 2008.
  • For facilities using non-cyanide electroplating, electroforming, or electropolishing with a pH < 12 S.U., the owner or operator must: (1) use wetting agent/fume suppressant (WAFS), control device, or tank cover; and (2) use management practices to minimize or eliminate potential emissions.
  • For facilities using flash or short-term electroplating, the owner or operator must: (1) use tank covers or limit plating time to 3 minutes per hour or 1 hour per day; and (2) use management practices to minimize or eliminate potential emissions.
  • For facilities using dry mechanical polishing and permanent thermal spraying, the owner or operator must exhaust emissions to a control device.

Management Practices to Minimize or Eliminate Potential Emissions, as Practicable

  • Minimize disturbances of the tank liquid when adding or removing parts processed in the tank.
  • Maximize drip time while removing parts from the tank. Use drain boards (also known as drip shields) or remove parts from the tank slowly.
  • Design barrels, racks, and other parts to minimize drag-out of bath solution (e.g., using slotted barrels and tilted racks, designing parts with flow-through holes to allow tank solution to drain back into the tank, etc.).
  • Use tank covers wherever practicable.
  • Minimize or reduce heating of process tanks wherever practicable
  • Perform regular repair, maintenance, and preventative maintenance on racks, barrels, and other associated equipment.
  • Minimize bath contamination however possible by not dropping parts, quickly recovering dropped parts, using distilled/de-ionized water, filtering the water, pre-cleaning parts before plating, and rinsing pre-treated parts before plating.
  • Ensure all chemicals and other bath ingredients are at the correct levels in the tank.
  • Perform general good housekeeping, such as regular sweeping or vacuuming and washdowns, as necessary.
  • Minimize spills and overflow of tanks, as practicable.
  • Use squeegee rolls in continuous or reel-to-reel tanks.
  • Perform regular inspections to identify leaks and other ways to prevent pollution.

Reporting

  • Prepare and submit an Annual Certification of Compliance (ACC) report by January 31 of each year for the previous calendar year.
  • Prepare and submit a Report of Deviations by January 31 of each year for the previous calendar year, if applicable.
  • Submit a completed Initial Notification form by July 1, 2008 for existing facilities, or by July 1, 2010 or initial startup for new facilities.
  • Submit a completed Notification of Compliance Status by July 2010 for existing sources, or upon initial startup for new facilities.

Recordkeeping

All owners and operators of plating or polishing operations subject to NESHAP 6W are required to maintain records of compliance for a period of five (5) years. These records include:

  • Copies of all submitted notifications and reports, along with all supporting data.
  • Records demonstrating compliance with the Management Practices to Minimize Potential Emissions.
  • For cyanide tanks, the one-time pH measurement value.
  • For non-cyanide tanks, the amount and frequency of WAFS additions, if applicable.
  • For short-term or flash electroplating tanks, the daily plating time.
  • For electroplating tanks using covers as a control option, the time the tank is operated with the cover in place.

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