EPA is proposing national emission standards for control of
hazardous air pollutants (HAP) for the plating and polishing area source
category. This rule proposes emission standards in the form of
management practices for new and existing tanks, thermal spray
equipment, and mechanical polishing equipment in certain plating and
polishing processes. These proposed standards reflect EPA's
determination regarding the generally achievable control technology
(GACT) and/or management practices for the area source category.
On March 6, 2008, the Environmental Protection Agency (EPA)
proposed national air toxics standards for smaller-emitting sources,
known as area sources, in the plating and polishing industry. Toxic air
pollutants, or air toxics, are known or suspected to cause cancer and
other health problems.
Area sources are commercial and industrial operations that release
lesser quantities of toxic pollutants into the air. Area sources emit
less than 10 t/yr of a single air toxic or less than 25 t/yr of a
combination of air toxics. Sources that emit more than these amounts are
characterized as "major" sources.
EPA is proposing standards for existing and new area sources in the
plating and polishing industry. The proposal would affect an estimated
2,900 existing plating and polishing facilities. The proposed rule
affects both management practices and reporting. The EPA will accept
public comment for 30 days after the proposal is published in the
Federal Register.
Proposal Summary
The proposed rule includes management practices such as the use of
wetting agent/fume suppressants in electroplating tanks and minimizing
agitation in all tanks, and equipment standards such as the capture and
control of emissions from thermal spray and dry mechanical polishing.
The rule will apply to plating and polishing tanks, dry mechanical
polishing operations, and thermal spray operations that use or emit
compounds of one or more of the following metal toxic air pollutants:
cadmium, chromium, lead, manganese, and nickel.
Plating tanks at area sources that are subject to the 2004 rule
"Chromium Emissions from Hard and Decorative Chromium
Electroplating and Chromium Anodizing Tanks" would not be subject
to this rule. Facilities in this industry would also be required to
submit one-time notifications of applicability and compliance status,
submit annual compliance certifications and deviation reports, and keep
records to demonstrate compliance with the proposed rule. EPA is not
proposing testing requirements.
Existing area source plating and polishing facilities are currently
well-controlled in terms of metal air toxics emissions as a result of
state and national standards, permitting requirements, OSHA workplace
standards, European pollution prevention, initiatives, and/or management
practices already taken by the industry to reduce air toxics. The
proposed rule would codify existing practices and the Agency does not
expect the rule would change the level of emissions control already
being achieved in the plating and polishing industry.
Since 1990, the plating and polishing industry has reduced their
air impacts by implementing voluntary controls. These controls have
reduced emissions of metal air toxics by approximately 95%. Although
there are no additional air emission reductions as a result of this
proposed rule, we believe that this proposed rule will assure that the
emission reductions made by the industry since 1990 will be maintained.
The proposed rule would have little cost impact on existing area
sources, averaging approximately $ 1,100 per facility/yr for the first
three years, for reporting and record keeping including one-time
notification costs. After the first three years, the annual costs are
approximately $722 per facility.
New sources, other than thermal spray operations, would be subject
to the same requirements as existing sources under this proposal. New
thermal spray operations would be required to control emissions with
filtration devices or the equivalent level of control; these devices are
used by the majority of existing thermal spray sources.
EPA is proposing to exempt area sources in the plating and
polishing operations industry from operating permit requirements called
Title V permitting requirements, except where an affected facility is
required to obtain a Title V permit for reasons other than being subject
to the proposed rule.
Background
The Clean Air Act requires EPA to identify categories of industrial
sources that emit one or more of 187 listed toxic air pollutants. These
industrial categories include both major and area sources. For major
sources within each source category, the Clean Air Act requires EPA to
develop standards that restrict emissions to levels consistent with the
lowest emitting (also called best-performing) plants. Major sources are
those that emit 10 t/yr or more of a single toxic air pollutant or 25
t/yr or more of a combination of air toxics.
For area sources within each source category, the Clean Air Act
allows EPA to develop standards or requirements which provide for the
use of generally available control technologies (GACT) or management
practices rather than the maximum achievable control technology (MACT)
required for major sources. Further, the Clean Air Act requires EPA to
(1) identify the toxic air pollutants that pose the greatest threat to
public health in urban areas and (2) identify and list the area source
categories that represent 90% of the emissions of the urban air toxics
associated with area sources and regulate them to ensure that the
emissions of these "urban" air toxics are reduced. EPA
implements these requirements through the Integrated Urban Air Toxics
Strategy.
EPA published the Strategy on July 19, 1999, in the Federal
Register that included:
* A list of the 33 air toxics that present the greatest threat to
public health in the largest number of urban areas. Of these 33 urban
air toxics, EPA has identified the 30 with the greatest contribution
from smaller commercial and industrial operations or "area"
sources, as defined in the Clean Air Act. (See
http://www.epa.gov/ttn/atw/urba n/list33.html for the full list.)
* A list of 29 area source categories that contribute to the
emissions of these 30 listed air toxics. Subsequent notices published on
June 26 and November 22, 2002, added 41 source categories to this list
of area sources and fulfilled the Clean Air Act requirement to identify
that list area source categories for at least 90% of the emissions of
the 30 "listed" (or area source) HAPs.
The Plating and Polishing source category included in today's
proposed rule is included in this list of area sources. For more
information, go to http:/www.epa.gov/ttn/atw/urban/urbanpg. html. To
download a copy of the notice, visit www.epae Web site at:
http://www.epa.gov/ttn/oarpg/t3pfpr.html. Today's proposed rule and
other background information are also available electronically at
http://www.regulations.gov (EPA's electronic public docket and
comment system). For further information about the proposed rule,
contact Dr. Donna Lee Jones, EPA Office of Air Quality Planning and
Standards (OAQPS) at (919) 541-5251 or e-mail: jones. donnalee@epa.gov.
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