Under the Pollution Prevention and Control Regulations 2000 (SI 2000/1973) the surface treatment industry sector (Section 2.3) is subject to regulation under PPC. This required operators of part or all of existing installations in this sector to apply for new integrated environmental permits between 1st May and 31st July 2004.
The Environmental Permitting Regulations came into force on 6th April 2008 and replace the IPPC permitting process. Full details are available on the Gov.UK website as follows:
The DEFRA PPC webpages can be accessed via the following link:
Applications had to set out how the operators were proposing to operate, what emissions and effects were likely as a result of their proposals and how they would apply Best Available Techniques. These applications represented a substantial challenge for both Industry and the Agency in terms of the resources that were needed to make and determine them. The SEA developed a club approach which allowed an Environment Agency sample permit application to be used by members of the club.
The sector is described in Section 2.3 Part A(1) (a) of Schedule 1 to the PPC Regulations, “listed activities”, as follows:
Surface treating metals and plastic materials using an electrolytic or chemical process where the aggregated volume of the treatment vats is more than 30 m3.
The following list summarises the types of immersion activity which do meet the description of “treatment” (i.e. cause chemical change to the surface) and so contribute to the aggregation total for comparison with the 30 m3 threshold:
Electroplating, electroless (autocatalytic) plating, anodising, passivation, electropolishing, pickling, activation, chromating, phosphating, bright dipping, chemical blacking, decorative oxidation, stripping (removal of plated metal), post-anodising sealing (both hot water and cold, e.g. with nickel acetate solutions), and surface etching (but not “chemical machining” where significant metal is removed for dimension change).
Electrolytic cleaning may meet the description if voltage conditions are changed such that metal is removed as ions instead of scale being eroded by hydrogen liberation.
The following do not meet the description of “treatment”:
Rinsing, subsequent weak acid or alkaline dips to remove residual alkalinity or acidity, respectively, from previous treatment stages, alkaline soak, electrolytic alkaline soak (except where the polarity is reversible and/or conditions favour metal corrosion), bacterial cleaning, colour dying, and electrophoretic lacquering or painting.
Cadmium plating processes using vats with a volume below 30 m3 are considered to fall under Section 4.2 Part A(1)(f), which had an application window of 1st October to 31st December 2004.