Electroplating Facilities

Chemical storage areas, testing laboratories, paint booths, paint mixing rooms, shipping and receiving areas, storage sheds, parking lots, and other outside areas where chemicals may be handled, stored, spilled, or illegally discharged to the ground can also present risks for environmental liability.

Many electroplating facilities have wastewater treatment systems. Collection systems for wastewater, such as drains, underground or aboveground piping, sumps, etc., can leak, impacting underlying soils and groundwater. Treatment system components, such as treatment tanks and piping, can be subject to sudden and accidental releases, resulting in various environmental risks.

Historic plating operations may differ from current plating operations in the toxicity of chemicals used and how chemicals are handled and stored. Past operations may have left lasting environmental impacts that result in on-site or off-site cleanup, bodily injury or property claims, or natural resource damage claims.

The metal plating industry historically has used and continues to use per-and polyfluoroalkyl substances (PFAS) in some metal plating applications, most notably in hard and decorative chromium plating, chromic acid anodizing, and chromium etch for plating on plastic processes. In 1995, the Environmental Protection Agency recommended using perfluorooctane sulfonate (PFOS) as a fume suppressant in chromium electroplating. Its use was eliminated by 2015; however, PFAS, including PFOS, has still been found to be present in wastewater generated from some plating operations. These substances are highly persistent, potentially impacting soil or groundwater, migrating over extensive distances in groundwater, impacting surface waters, or being discharged in wastewater to public treatment systems. On-site and off-site cleanup, third-party bodily injury and property damage, non-owned disposal facility, and natural resource damage claims exposures could result from these past and present uses.

Chlorinated solvents were often used at electroplating facilities to degrease and clean parts before plating. Chlorinated solvents can migrate through concrete surfaces and are persistent in the environment. These chemicals can also present a vapor intrusion risk, impacting indoor air quality. On-site and off-site cleanup, third-party bodily injury and property damage, non-owned disposal facility, and natural resource damage claims exposures could result from their past use.

Electroplating operations generate fugitive and stack air emissions and may require wet scrubbers to control emissions. If stack emissions are not properly controlled, stack emissions could be distributed over a wide area before settling out of the air. Building materials, soil, groundwater, and stormwater near vapor collection exhaust systems may have residual concentrations of metals. On and off-site cleanup and third-party claims could result from impacts from air emissions.

Stormwater run-off from electroplating facilities could come in contact with chemicals, debris, wastes, and other outside storage, contaminating soil, groundwater, and natural resources, such as rivers, lakes, and streams.

Hazardous wastes are typically generated from operations at electroplating facilities. Spills or releases can occur during handling or storage, resulting in exposure to cleanup, third-party, or natural resource damage claims. Additionally, off-site disposal of these wastes can lead to liability for the cleanup of non-owned disposal facilities.

Often electroplating facilities are located in industrial areas within a city. Contaminants from neighboring facilities could migrate to the manufacturer’s property. If the neighboring business owner is not properly insured or goes bankrupt, the cost of cleanup could fall on the owner of the electroplating facility.

Accidental releases can occur when transporting chemicals used in the electroplating process or wastes generated by the operations. Improper cargo securement, a loose valve, or vehicle accidents can result in spills of these chemicals or wastes that could result in a pollution condition, third-party claims, or natural resource damage claims.