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Proposed air toxics standards for area sources in the plating and polishing industry.

Advanced Materials & Processes • August, 2008 •

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.


COPYRIGHT 2008 ASM International Reproduced with permission of the copyright holder. Further reproduction or distribution is prohibited without permission.
Copyright 2008 Gale, Cengage Learning. All rights reserved. Gale Group is a Thomson Corporation Company.
NOTE: All illustrations and photos have been removed from this article.


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