Plating and Polishing

The Environmental Protection Agency published new regulations on July 1, 2008, that impact plating and polishing facilities. The Federal National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations 40 CFR 63 Subpart WWWWWW rule (6W) was issued to reduce vapors from facilities that contain cadmium, chromium, manganese, nickel, lead, and other harmful chemicals. It does NOT affect processes 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. For example, if a facility has a tank for chrome electroplating and another for electroless nickel plating the facility would need to comply with both Subpart N and Subpart 6W in regards to the two different tanks. Please note that many of the requirements are similar, with Subpart N being somewhat more stringent. By July 1, 2010, facilities affected by the rule are required to be in compliance with the rule.

EPA has a website with additional resources for the Plating and Polishing rule.

Important dates

  • Initial Notification: Existing Facilities: October 29, 2008. New Facilities: within 120 days after becoming affected by rule.
  • Notification of Compliance Status: Existing Facilities: July 1, 2010. New Facilities: upon startup of the affected source.
  • Annual Compliance Certification Report: Prepared by January 31 of the year following the reported year. For existing sources, the first reported year would be 2010.

Notification of Compliance Status

The Notification of Compliance Status report is required to be submitted by July 1, 2010 for existing facilities (constructed on or before March 14, 2008) to both the EPA Region IV and the State of TN Division of Air Pollution Control. 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. This report provides information on what processes are affected by the rule and what the facility is doing to meet the requirements of the rule. A sample Notification of Compliance Status report is available.

To further assist a facility in determining their compliance requirements, a Compliance Checklist has been developed as an aid.

Annual Compliance Certification Report

If you own or operate an affected source, you must prepare an annual compliance certification report by January 31st of the year immediately following the year to be reported. For existing sources, the first year to be reported is 2010 and the annual compliance certification report needs to be prepared by January 31, 2011. These reports do not need to be submitted unless a deviation from the requirements of this rule has occurred during the reporting year, in which case, the annual compliance certification report must be submitted along with the deviation report on the January following the year in which there was a deviation. Though the report does not need to be submitted unless there is a deviation, they still have to be prepared and kept onsite in the event that an inspector requests the report. The 6W rule requires recordkeeping in order to support the statements made in the annual compliance certification report. An example of the records needed and an annual compliance certification report is available.

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 is available.

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 is affected by the rule?

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 affected by the rule?

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.