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EPA Plating and Polishing Area Source Final Rule Notification Deadline Looms

On July 1, 2008, EPA published the final regulation for plating and polishing area sources in the Federal Register (73 Fed. Reg. 37728). The final rule, 40 CFR Part 63, Subpart WWWWWW, is effective immediately for new affected sources (i.e., those that begin operations on or after July 1, 2008). Under the new plating and polishing rule, owners and operators of affected sources must comply with several notification and recordkeeping requirements. An initial notification must be submitted to the EPA or an authorized state agency no later than Oct. 29, 2008. Existing plating and polishing operations must comply with the new regulatory requirements by July 1, 2010.

The notification should include the following:

  • Name and address of the owner or operator the location of the facility
  • The relevant applicable air emission standard for the facility
  • A brief description of the affected source, the fact that the facility is an area source, and the compliance method for each affected source.
The plating and polishing processes that are subject to the plating and polishing area source rule are those “processes performed at an affected plating and polishing facility that uses or has the potential to emit” any compound of any of the following metal HAPs:  cadmium, chromium, lead, manganese, and nickel. This includes electrolytic and non-electrolytic plating and coating processes ( e.g., electroplating, conversion coating, sealing, and phosphating), electroforming, dry mechanical polishing, and thermal spray at approximately 2,900 existing plating and polishing facilities. 
 
As a result of the efforts of the National Association for Surface Finishing (NASF), EPA did not establish emission limits for plating and polishing operations, but required plating and polishing facilities to follow management practices as the generally available control technology (GACT) standards. EPA also acknowledged in the preamble to the final rule that not all of the management practices may be practicable for some processes due to production and product quality concerns. 
 
In addition to the management practices discussed above, the final rule has other regulatory requirements for some specific plating and polishing processes, such as the use of wetting agents, tank covers, and emission control devices.
 
Existing sources must also submit a notification of compliance status by July 1, 2010, and an annual certification of compliance in subsequent years that includes a description of how the facility has complied with the applicable regulatory provisions. The certification should also report any deviations from the compliance requirements during the year and any corrective actions taken to remedy the deviation.
 
A copy of the final rule, a summary of the new regulatory requirements, and a sample notification letter are available to NASF members on the NASF website, www.nasf.org

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