EPA to Clarify 6W Rule at EN Conference


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Donna Lee Jones, Ph.D., the senior technical advisor in the metals sector for the U. S. Environmental Protection Agency’s Office of Air Quality Planning and Standards, will be delivering the EN Conference’s keynote address on the EPA’s new rules on electroless nickel.

The talk will start at 11 a.m. on Tuesday, Nov. 9. A question-and-answer period will follow a brief summary of the rule and update of compliance activity since promulgation.

Dr. Jones’ address will discuss the management practices that need to be implemented to be in compliance of the new rule, as well as verification of what is and what is not subject to the rule.
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The EPA in 2008 issued national emission standards for control of hazardous air pollutants (NESHAP) for the plating and polishing area source category (40 CFR, part 63, subpart WWWWWW).

This rule went into effect this July for existing sources. These final emission standards reflect EPA’s determination regarding the generally achievable control technology (GACT) and management practices for this area source category.

The plating and polishing rule established emission standards in the form of management practices for new and existing plating and polishing tanks, thermal spraying equipment, and mechanical polishing equipment that use or emit compounds of one or more of the following metal toxic air pollutants: cadmium, chromium, lead, manganese, and nickel.

The final rule includes management practices such as the use of wetting agent/fume suppressants and requires equipment standards such as the use of tank covers or control devices, and the capture and control of emissions from thermal spraying and dry mechanical polishing.

The rule does not require any emissions testing. Facilities in this industry are required to submit one-time notifications of applicability and compliance status; submit deviation reports if a deviation occurred during the year; and keep records to demonstrate compliance with the rule.

Plating tanks at area sources that are subject to the 2004 rule “Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks” are not subject to this rule.

To Whom Does The 6W Rule Apply?

Facilities that are area sources of hazardous pollutants (HAP) Tanks/ processes that contain or use any compounds of cadmium (Cd), chromium (Cr), manganese (Mn), nickel (Ni) or lead (Pb), in the following processes:

Non-cyanide electroplating and electroforming (pH<12), and electropolishing
Cyanide plating (pH ≥12)
Electroless plating
Other coating, such as chromium conversion coating
Thermal spraying
Dry mechanical polishing