**Brief Summary**

**New EPA Regulations for**

**Plating and Polishing Facilities**

**[40 CFR Part63 Subpart WWWWWW]{.underline}**

EPA has new requirements to reduce air pollution from plating and
polishing facilities. The vapor from these facilities contain Cadmium,
Chromium, Manganese, Nickel, Lead, and other harmful chemicals that pose
a health risk to anyone who breathes air containing them.

This is a short summary of things that plating and polishing operations
must do to comply with the new rule requirements. For more details and
assistance, please talk to your local environmental contact.

**Specific Requirements**

-   Compliance dates: Existing sources by 07/01/10; New sources upon
    start-up

-   Non-cyanide electroplating, electroforming or electropolishing with
    pH\<12

    -   Use wetting agent/fume suppressant (WAFS), control device or
        tank cover

    -   Management practices to minimize or eliminate potential
        emissions

-   Flash or short-term electroplating

    -   Use tank covers or limit plating time to 3 min/hr or 1 hr/day

    -   Management practices to minimize or eliminate potential
        emissions

-   Dry mechanical polishing and thermal spraying (permanent operations)

    -   Exhaust emissions to a control device

-   Cyanide electroplating (pH ≥12), non-electrolytic plating and
    coating operations (such as electroless nickel plating and chromate
    conversion coating), and temporary thermal spraying:

    -   Management practices to minimize or eliminate potential
        emissions

**Management Practices to Minimize or Eliminate Potential Emissions, as
Practicable**

> • Keep tank liquid as still as you can when removing parts processed
> in the tank.
>
> • Make the drip time as long as you can when removing parts from the
> tank. Use drain boards (also known as drip shields) or remove parts
> slowly from the tank.
>
> • Design barrels, racks, and parts to minimize dragout of bath
> solution (such as by using slotted barrels and tilted racks, or by
> designing parts with flow-through holes to allow the tank solution to
> drip back into the tank).
>
> • Use tank covers whenever you can.
>
> • Minimize or reduce heating of process tanks whenever possible.
>
> • Perform regular repair, maintenance, and preventive maintenance of
> racks, barrels, and other equipment.
>
> • Minimize bath contamination however possible by not dropping parts
> or quickly recovering dropped parts, using distilled/de-ionized water,
> filtering the water, pre-cleaning the parts before plating and rinsing
> pre-treated parts before plating.
>
> *(continued)*
>
> • Make sure that the chemicals and other bath ingredients are at the
> correct levels in the tank.
>
> • Perform general good housekeeping, such as regular sweeping or
> vacuuming, if needed, and washdowns when needed.
>
> • Minimize spills and overflow of tanks as much as possible.
>
> • Use squeegee rolls in continuous or reel-to-reel plating tanks.
>
> • Perform regular inspections to identify leaks and other ways to
> prevent pollution.

**Reporting**

> • Prepare Annual Certification of Compliance report by January 31^st^
> of each year for the previous year. Submit by January 31^st^ if any
> deviations occurred during the previous year.
>
> • Prepare and submit Report of Deviations by January 31^st^ of each
> year, if applicable.
>
> • Submit Initial Notification:
>
> • Existing sources on 10/29/08
>
> • New sources on 10/29/08 or upon startup (*correction: note rule will
> be revised)*
>
> • Submit Notification of Compliance Status:
>
> • Existing sources on 07/01/10
>
> • New sources upon start-up

**Recordkeeping**

> • All required notifications and reports, with supporting data.
>
> • Records that show you meet the management practices.
>
> • For cyanide tanks, provide the one-time pH measurement value.
>
> • For non-cyanide tanks, provide 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 cover in place.

-   Records must be kept for a period of 5 years.

**More Information**

For more details and assistance, please talk to your local environmental
contact. These web links to government contacts are a good place to
start:

-   <http://www.epa.gov/ttn/atw/area/regional_contacts.pdf>

<http://www.smallbiz-enviroweb.org/sba/sbap.html>

The rule itself can be found at this link:

<http://www.epa.gov/ttn/atw/area/arearules.html>