The United States Environmental Protection Agency (EPA) is taking the first step toward developing new air emissions standards for plating and polishing facilities.
The agency is required under section 112 of the Clean Air Act to develop hazardous air pollutant (HAP) emission standards for area sources that include the plating and polishing source category. EPA says this source category includes “establishments primarily engaged in all types of electroplating, electroless plating, polishing, thermal or metal spraying, anodizing, coloring and finishing of metals and formed products for the trade.”
The federal judicial system has also gotten into the act. EPA is under a court order to promulgate more than 50 new area source category HAP standards in the next three years. The agency wants to complete work on a final rule for the plating and polishing source category by June 2008 at the latest.
An EPA official provided a summary of the latest developments in this area at the SFIC Washington Forum held in May. According to Donna Lee Jones, EPA has already sent an information request questionnaire to hundreds of metal finishing facilities.
The agency hopes the questionnaires will be a first step toward evaluating the types of provisions that may be needed to limit HAP emissions for the plating and polishing source category. EPA is hoping to use the information gained to make an informed decision about how to go about developing an appropriate regulation for the plating and polishing source category. Unfortunately, the survey specifically requests air emissions data. Few facilities are likely to have much, if any, data with complete air emissions test reports.
So what should you do about the survey, if you’ve received one? If you don’t have air emissions data, you simply state that it is not available. No additional testing or monitoring is required at this point.
The questionnaire also will ask about the type of plating and polishing processes your facility performs, any HAP-containing materials you use and the pollution prevention and control practices you have in place. This information will serve as the basis for EPA’s evaluation of its regulatory options and the potential impacts of these options.
The questionnaire applies only to HAPs. If materials you work with are not listed as HAPs, you needn’t provide information. Also exempt are some HAP emissions EPA has already determined to be insignificant, such as acid emissions from pickling and cleaning tanks.
Chromium emissions from electroplating and anodizing tanks regulated under the existing chromium MACT standard also will not be addressed under the plating and polishing source category. EPA is, however, seeking information about emissions from currently unregulated processes such as chromate conversion coatings.
How all this eventually shakes out remains to be seen, of course. But, given the EPA’s mandate from both Congress and the courts, it’s clear some kind of air emissions regulations for platers are coming down the pipeline. Stay tuned.