One of our customers is considering setting up a new bright nickel plating line that has been developed to replace chrome plating at its new location in Virginia. My question is do they need to obtain an air quality permit in order to operate?P.C.
While nickel plating does not have a national air pollution control standard like the chrome plating maximum achievable control technology (MACT) standard, it still may be regulated by your state’s department of environmental quality (DEQ). In order to determine if the process requires a permit, I recommend that your customer contact their regional air pollution office and obtain information regarding permit exemptions and emission thresholds.
The state DEQ likely has a list of exempted sources. If nickel plating is listed (it is not), then no permit is required.
Many states have permit emission thresholds (Virginia does). That is, if your emission rate is below a certain threshold, no permit is required. Because nickel is regulated as a hazardous air pollutant by many states (it is by Virginia), it will likely have a threshold based upon its occupational health Threshold Limit Value (TLV) or Permissible Exposure Limit (PEL). Virginia uses the TLV.
To estimate nickel emissions, we have used an emission rate of 0.225 milligrams nickel/amp-hr based upon a National Association of Metal Finishers membership advisory dated May, 1991, to estimate air emissions from open nickel plating tanks for the annual SARA 313 – Toxic Chemical Release report.
Even if you find that the emission rate is below its permit threshold, the state DEQ may still require that a permit application for this process be made in order to document that a permit-to-construct and a permit-to-operate is not needed. If this is the case, and I suspect it is because of our recent experience, I recommend that the application be made before any construction or installation of this source begins.