Plating and Polishing Operations

40 CFR 63, Subpart 6W

The U.S. EPA, Region 5, has conducted inspections of some businesses with respect to 6W since this rule became effective. The inspections resulted in citations for missing records pertaining to the maintenance of non-cyanide electroplating, electroforming and/or electropolishing tanks and the periodic additions of a wetting agent/fume suppressant. The U.S. EPA approached the Region 5 Small Business Environmental Assistance Programs (SBEAPs) in Illinois, Indiana, Michigan, Minnesota, Ohio and Wisconsin, to encourage these states to work closely with the industry to help them understand what records need to be kept and what notifications to submit. This is an ongoing outreach project. Indiana has made outreach efforts and has Compliance and Technical Assistance Program (CTAP) staff available to assist businesses with questions.

What does it affect?

This regulation affects emissions of Cadmium, Chromium, Lead, Manganese, and/or Nickel from any of the following operations:

  • Cadmium, lead, nickel, or lead electroplating
  • Electroless nickel plating *
  • Electroforming
  • Electropolishing
  • Chromate conversion coating *
  • Manganese phosphating *
  • Nickel acetate sealing *
  • Sodium dichromate sealing *
  • Thermal metal spraying
  • Dry mechanical polishing after plating

* Subject only to applicable management practices, as practicable, as well as reporting and recordkeeping.

What is exempt from this regulation?

This regulation exempts the following operations:

  • Hard and decorative chromium electroplating
  • Chromium anodizing
  • Plating and polishing conducted for:
    • Research and development
    • Education
    • Repair of surfaces or equipment
    • Restoration of the original finish
  • Dry mechanical polishing prior to plating
  • Trace quantities of any one of the five (5) metals

Please note a business is exempt from this regulation if it has been determined to be a major source of hazardous air pollutants (HAP).

Control and Management Practices

The following resources contain further information regarding control and management practices of specific operations.

IDEM Resources