NESHAP_6W

Subpart WWWWWW—National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations
Regulation: 40 CFR 63.11504 - .11512
Applicability
  • You are subject to this subpart if :
  •  You are an Area Source (Not Major Source) Note: An area source of HAP emissions is any stationary source or group of stationary sources within a contiguous area under common control that does not have the potential to emit any single HAP at a rate of 9.07 megagrams per year (Mg/yr) (10 tons per year (tpy)) or more and any combination of HAP at a rate of 22.68 Mg/yr (25 tpy) or more.
  •  You operate a plating and/or polishing facility, is a plant site that is engaged in one or more of the processes:
  •  Electroplating other than chromium electroplating (i.e., non-chromium electroplating).
  •  Electroless or non-eletrolytic plating.
  • Other non-electrolytic metal coating processes, such as chromate conversion coating, nickel acetate sealing, sodium dichromate sealing, and manganese phosphate coating; and thermal spraying.
  •  Dry mechanical polishing of finished metals and formed products after plating.
  •  Electroforming.
  •  Electropolishing.
  •  Your plating and polishing facility uses or has emissions of compounds of one or more plating and polishing metal HAP, which means any compound of any of the following metals:
    • cadmium,
    • chromium,
    • lead,
    • manganese,
    • nickel,
 

 
Exemption
This subpart does not apply to any of the process units or operations:

(1) Process units that are 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) Research and development process units, as defined in §63.11511, “What definitions apply to this subpart?”

(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 to apply to restoring the original finish.

(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.
New V. Existing Sources
EXISTING Source - An affected source is existing if you commenced construction or reconstruction of the affected source on or before March 14, 2008.

NEW SOURCE - An affected source is new if you commenced construction or reconstruction of the affected source after March 14, 2008.
Compliance Dates
EXISTING SOURCES - you must achieve compliance with the applicable provisions of this subpart no later than July 1, 2010.

NEW SOURCES - If you own or operate a new affected source for which the initial startup date is on or before July 1, 2008, you must achieve compliance with the provisions of this subpart no later than July 1, 2008.

NEW SOURCE - If you own or operate a new affected source for which the initial startup date is after July 1, 2008, you must achieve compliance with the provisions of this subpart upon initial startup of your affected source.
Specific Standards Non-cyanide electroplating, electroforming, or electropolishing tank - Use wetting agent/fume suppressant, control device or tank cover.

Flash or Short term Tank - Limit plating time to 3 min/hour, or 1 hour / day or use  tank cover.

Other coating & Plating - Management practices

Dry Mechanical Polishing & Thermal Spraying - Exhaust emissions to a control device
Management Practices  
Reports
  •  Initial Notification
  •  Notification of Compliance Status
  •  Annual Certification of Compliance
  •  Report of Deviation (if needed)
Recordkeeping
  •  Records to demonstrate compliance with management practices (Monthly checklist)
  •  For Cyanide tanks - record initial pH of bath
  •  For Non-Cyanide tanks - amount & Frequency of WAFS additions.
  •  For Short Term tanks - the daily plating time
  •  For Batch Tanks with Covers - the daily plating time
  •  For Continuous plating tanks - the amount of tank surface area covered, and the time tank is operated with the cover in place.
  •  Operating manuals for all required control systems
  •  All required notifications and reports
Report Dates Initial Notification -
  •  Existing Sources - 10/20/08
  •  New Sources - Upon start-up

Notification of Compliance Status

  •  Existing Sources - 07/10/2010
  • New Sources - Upon Start-up
For Additional Information, contact Mounce & Associates, Inc. 972-492-3911 x204, steve@mounce.net

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