Compliance Status Report Due For Plating and Polishing Operations

On or before July 1, 2010, plating facilities subject to the plating or polishing operations National Emission Standards for Hazardous Air Pollutants (NESHAP) will have to submit their Notification of Compliance Status. In 2008, EPA published the NESHAP for Plating and Polishing Operations, which impacted many metal finishing operations, including facilities with plating, polishing or thermal spray processes that contain cadmium, nickel, lead, manganese and/or chromium.

The rule specifies several notification, recordkeeping and reporting requirements:
• Submit an Initial Notification by Oct. 29, 2008.
• Submit a Notification of Compliance Status by July 1, 2010 for existing processes, or at startup for new processes.
• Submit an annual compliance certification and,
• Submit an annual deviations report, if applicable.

EPA did not establish emission limits for plating and polishing operations, but required plating and polishing facilities to follow management practices as the generally available control technology (GACT) standards. The rule requires owners or operators of affected plating and polishing operations to demonstrate continuous compliance by adhering to the management and pollution prevention practices specified in the rule, and by maintaining the appropriate records to document their compliance.

Caltha LLP provides specialized expertise to clients nationwide in the preparation of regulatory reporting documents, developing EH&S compliance procedures, and preparing cost-effective compliance management programs.

For further information contact Caltha LLP at

info@calthacompany.com

or

Caltha LLP Website