Pat Quinn, Governor
Electroplating Shops - Watch Your Waste!
Regulatory Compliance and Pollution Prevention Tips
Information presented in this publication is intended to provide a general understanding of the statutory and regulatory requirements governing electroplaters. This information is not intended to replace, limit or expand upon the complete statutory and regulatory requirements found in the Illinois Environmental Protection Act and Title 35 of the Illinois Administrative Code.
Why are electroplating wastes a concern?
Electroplating wastes are potentially hazardous to human health and the environment when they are improperly managed. Several special and hazardous wastes are commonly generated by the electroplating industry. The "Do I Have a Special Waste?" fact sheet defines and discusses special wastes. In Illinois, electroplating wastes are special wastes because they are industrial process wastes and may also be hazardous. This fact sheet will help you determine the hazardous waste, air, and water regulations that apply to your electroplating operations and how to properly manage your waste to protect your employees, the community, and the environment.
What are the regulatory definitions of Electroplating and Metal Finishing?
Electroplating [40 Code of Federal Regulations (CFR) 413] covers job shop facilities. A plant is considered a job shop facility if at least 50 percent of the parts it processes are made elsewhere. Metal finishing (40CFR 433) covers facilities that can be either job shops or captive shops. Over 50 percent of the parts used in a captive shop facility are made at the facility. Generally, electroplating is only one step in the processes at a captive shop (metal finishing shop).
Hazardous Waste Regulations
Are electroplating wastes hazardous?
"Do I Have a Special Waste?" fact sheet defines hazardous waste and
will help you determine if your waste is characteristic for ignitability,
corrosivity, reactivity, or toxicity, or if it is listed. Some common
U.S. Environmental Protection Agency (EPA) waste codes for hazardous electroplating
wastes are listed in Table 1. For a detailed hazardous waste list, call the
Office of Small Business.
Your wastes are hazardous if one of the following applies to you:
What types of regulations apply to my electroplating shop?
Hazardous solvents, liquids, and sludges must be managed by a hazardous waste transporter and a treatment or disposal company in accordance with hazardous waste requirements. The fact sheet "How Do I Manage My Hazardous Waste?" will help you determine what type of hazardous waste generator you are and what general hazardous waste requirements apply to you, such as labeling, manifesting, and storage requirements. Generators of special waste are responsible for completing an annual waste report if 1) they ship their waste out of state or 2) if the waste is hazardous. In addition, listed below are common compliance issues that your electroplating shop should follow.
Do air regulations apply to my shop?
Air regulations apply to all electroplating shops. All electroplating facilities in Illinois require an air pollution control permit. Most emissions from electroplating and anodizing baths come from fine mists formed by the process. If the mist is reduced, emissions are reduced. Another source of emissions is from solvents used in various processes such as vapor degreasing, lacquering operations, and phosphating.
Electroplating shops may also be affected by federal regulations. The Clean Air Act (CAA) regulates air emissions of 189 toxic chemicals. To control emissions of these chemicals, EPA issued National Emission Standards for Hazardous Air Pollutants (NESHAP) for particular industries, including the electroplating industry. NESHAP regulates chromium emissions from hard and decorative chromium electroplating and chromium anodizing tanks. NESHAP contains standards that covers emissions limits, work practices, initial performance testing, ongoing compliance monitoring, recordkeeping, and reporting.
Does my business need an air pollution control permit?
Construction permits are required prior to beginning construction of an emission source or air pollution control equipment. Operating permits are required for operation of an emission source or air pollution control equipment subject to the permit requirements. Even if your business did not have a construction permit prior to construction of your emission source, you may be required to have an operating permit. If you have air pollution control equipment, you have an emission source.
What type of operating permit is required?
Lifetime permits are for small companies that do not cumulatively emit 25 tons per year of all contaminants including less than 10 tons of any Hazardous Air Pollutant (HAPs) or 25 tons per year combined HAPs.
Federally Enforceable State Operating Permits (FESOPs) are permits with enforceable conditions to avoid the Title V or Clean Air Act Permit Program (CAAPP) permits. These permits have enforceable conditions that limit the businesses emissions to less the CAAPP thresholds.
CAAPP permits are for major air emission sources. If you potentially emit 25 tons per year of volatile organic compounds (VOCs) or 100 tons of other contaminants (nitrogen oxide, carbon monoxide, sulfur dioxide and particulate matter) in an ozone nonattainment area, you have a major source and must apply for a CAAPP permit. If you potentially emit 100 tons per year of VOCs or the other contaminants in an attainment zone, you must apply for a CAAPP permit.
In addition, if you potentially emit 10 tons per year of a single hazardous air pollutant (HAP) or 25 tons per year of combined HAPs, you must apply for a CAAPP permit. Other rules may also require you to apply for a CAAPP permit. For more information on air permits, contact the Office of Small Business and see the Illinois EPA fact sheet "Does My Business Need an Air Pollution Control Permit."
Which specific water regulations apply to my electroplating shop?
Spent solutions and wastewater may be discharged to your city’s sanitary sewer if they meet local, state, or federal discharge limits or with permission from your local publicly owned treatment works (POTW). The federal discharge regulations for electroplating indicate a single day maximum and a 4-day average. The federal discharge regulations for metal finishing indicate a single day maximum and a 30-day average. For a list of the federal discharge limits, contact the Office of Small Business. The POTW or city sewer may have pretreatment regulations. Contact them to determine discharge limits and compliance monitoring requirements. You may also be required to submit semiannual or more frequent compliance sampling and reporting information. Spent solutions or wastewater should never be discharged to a septic system or storm water sewer.
If wastewater is discharged to a sanitary sewer system, the business owners must apply for a state construction permit and may also need to apply for a state operating permit. Contact the Office of Small Business for more information on Illinois EPA water permits.
Are there pollution prevention (P2) techniques that I can implement in my shop?
Electroplaters can use many P2 techniques and technologies to reduce pollution
and operating costs within their shops. These options are often inexpensive
and usually have payback periods of less than 2 years!
A common P2 target for electroplaters is to reduce dragout. Methods to reduce dragout are summarized below.
Reduce Water Use
Another P2 technique is to reduce water use, which will result in lower water purchase costs, less wastewater generation, and lower wastewater treatment costs. Continuously flowing rinse water is not always needed! Methods to reduce water use are summarized below.
Extend Bath Life
Process baths can be costly for electroplaters to manage. With proper bath maintenance, process bath life can be greatly extended. Some techniques to extend process bath life are summarized below.
How do I obtain more information?
For more information on electroplating wastes, applicable regulations, and where to receive other fact sheets, call the Office of Small Business Helpline toll-free at (888) 372-1996 or the DCCA Small Business Environmental Assistance Helpline at (800) 252-3998. All calls are considered confidential, and the caller can remain anonymous. Technical assistance is also provided by the Waste Management Research Center at (217) 333-8940.
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