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EPA's New Regulation Controlling Air Emissions From
Chromium Electroplating And Anodizing Tanks

Introduction

November 1994, the U.S. Environmental Protection Agency (EPA) finalized regulations known as the National Emission Standards for Hazardous Air Pollutants (NESHAP) to control air emissions of chromium electroplating and chromium anodizing tanks. NESHAP, Subpart N affects ALL facilities performing hard or decorative chromium electroplating and chromium anodizing, regardless of size. The EPA estimates that these regulations will reduce chromium emissions by electroplaters and anodizers by about ninety-nine percent.

Why is EPA regulating electroplating and anodizing tanks?

The hexavalent form of chromium is highly toxic and strongly suspected of causing lung cancer. Less is known about the trivalent form of chromium, but it can accumulate in the lungs and may decrease lung function after continuous exposure. The EPA believes that the high toxicity of chromium compounds and the close proximity of many small shops to residential areas warrant regulation of all sources, even small businesses.

How does the new EPA regulation affect you?

How you are affected depends on the type and size shop you have and the technique used to reduce emissions. The source categories being regulated are:

    hard chromium electroplating

  • one step process depositing a thick layer of chromium
  • functional characteristics: corrosion and wear resistant
  • examples: hydraulic cylinders, industrial rolls
  • decorative chromium electroplating

  • one in a series of plating steps each depositing a thin layer of chromium
  • decorative characteristics: bright, reflective finish, tarnish and wear resistant
  • examples: auto bumpers, bathroom fixtures, tools
  • chromium anodizing

  • process by which an oxide film is formed on the surface of aluminum electrolytically
  • characteristics: aluminum part is strong, lightweight, and highly corrosion resistant
  • examples: aircraft parts, electronic parts, bicycle parts

Decorative chromium electroplating operations must be in compliance with the regulation by January 25, 1996. Hard chromium electroplating and chromium anodizing operations must be in compliance by January 25, 1997. In general, the regulation requires:

  • emission limits
  • ongoing monitoring
  • work practice standards
  • record keeping
  • initial testing
  • reporting

U.S. EPA has published a guidebook entitled "A Guidebook on How to Comply with the Chromium Electroplating and Anodizing National Emission Standards for Hazardous Air Pollutants" (EPA-453/B-95-001) that provides a more detailed explanation of the regulation. Also available is U.S. EPA's brochure called "EPA's New Regulation Controlling Air Emissions From Chromium Electroplating and Anodizing Tanks."

Emission Limits

Most emissions from chromium electroplating and chromium anodizing baths are found in the fine mists formed by the process. Therefore, reducing mist reduces emissions. This can be achieved through chemical or mechanical means.

To comply with the NESHAP, you may choose from the following control methods:

  • composite mesh pad (CMP) system
  • packed bed scrubber
  • fiber-bed mist eliminator
  • wetting agent-type fume suppressant
  • foam blanket

Even though these control methods form the basis for the standard, you may use any method as long as you are able to demonstrate that it meets the emission limit that applies to your tank.

Affected Tanks

Emission Limits

Emission Reduction Technique

Hard Chromium Plating Tanks

small, existing tanks*

0.03 mg/dscm

Packed-bed scrubber (PBS)

all other tanks

0.015 mg/dscm

Composite mesh-pad (CMP)system

Decorative Chromium Plating Tanks Using a Chromic Acid Bath

all tanks

0.01 mg/dscm or 45 dynes/cm

Fume Suppressant (FS) that contains a wetting agent

Decorative Chromium Plating Tanks Using a Trivalent Chromium Bath

all tanks

Only subject to recording keeping and reporting

Chromium Anodizing Tanks

all tanks

0.01 mg/dscm or 45 dynes/cm

FS that contains a wetting agent

* Small tanks have a maximum potential rectifier capacity of less than 60 million ampere-hours per year. Existing tanks were installed prior to 12/16/93.

Work Practice Standards

The regulation specifies work practice standards, which include:

  • preparation of an operational and maintenance plan
  • quarterly inspections of control devices, ductwork, and monitoring equipment
  • periodic wash down of composite mesh-pad systems
  • fresh water additions to the top of packed-bed scrubbers

Initial Testing

A one time test is required by July 23, 1996 for decorative chromium platers and by July 24, 1997 for hard chromium electroplaters and chromium anodizers to demonstrate that you are meeting the emission limit for your type of operation. During testing, you are required to establish operating parameters (e.g., pressure drop or foam thickness) that correspond to compliance with the emission limit.

Sources that meet the following criteria do not have to perform initial testing:

  • decorative chromium plating tanks or chromium anodizing tanks that use a wetting agent and limit the surface tension of the bath to 45 dynes per centimeter (dynes/cm)
  • decorative chromium plating tanks that use a trivalent chromium bath

Ongoing Monitoring

Continuous compliance with the regulation is demonstrated through ongoing monitoring of the operating parameters established during initial testing. The monitoring requirements vary depending on the type of emission reduction technique that you use.

Emission Reduction Technique

What to Monitor

How Often

CMP

Pressure drop across unit

Once per day

PBS

Inlet velocity pressure and pressure drop across unit

Once per day

CMP/PBS

Pressure drop across unit

Once per day

Fiber-bed Mist Eliminator (FBME)

Pressure drop across FBME and across upstream unit

Once per day

Wetting Agent

Surface tension of bath

Once every four hours

Foam Blanket

Foam thickness

Once per hour

Record Keeping

The regulation requires that sources keep records to document compliance with the regulation. These include inspection records, equipment maintenance records, records of malfunctions and exceedances, performance test results, and monitoring data. All records must be kept for five years.

If you operate a decorating chromium plating tank that uses a trivalent chromium bath, you only need to keep records of bath component purchases.

Reporting

The extent and frequency of reporting depends on the type and size of your source.

Requirement

Date

All Tanks

Initial Notification

7/24/95

Decorative Chromium Plating Using a Chromic Acid Bath

Compliance Deadline

1/25/96

Testing Deadline

7/23/96

Notification of Performance Test

>= 60 days before test

Notification of Compliance Status

<= 90 days after test or 2/24/96 if no test is required

Notification of Test Results

<= 90 days after test

Decorative Chromium Plating Tanks Using a
Trivalent Chromium Bath

Notification of Compliance Status

2/24/96

Notification of Process Change

<= 30 days after change

Hard Chromium Plating and Chromium Anodizing Tanks

Compliance Deadline

1/25/97

Testing Deadline

7/24/97

Notification of Performance Test

>= 60 days before test

Notification of Compliance Status

<= 90 days after test or 2/24/97 if no test is required

Notification of Test Results

<= 90 days after test

Pollution Prevention

The simplest way to lessen the impact of this regulation on your business is to reduce chromium emissions. If you use trivalent chromium instead of hexavalent chromium you will reduce both the toxicity of your emissions and the complexity of the regulatory burden. Although still regulated, trivalent chromium is not as toxic nor as stringently regulated as hexavalent chromium.

In addition, each of the add on emission reduction techniques has a recycling element; they allow for recycling of all collected chromium and/or reducing the total wastewater treatment burden of a facility.

The Ohio EPA's Office of Compliance Assistance and Pollution Prevention (OCAPP) is designed to help businesses with less than 100 employees comply with air pollution laws and regulations. We can assist you in determining what air pollution permits are required for your business as well as helping you complete the application forms. We also offer on-site evaluations, pollution control and prevention information, and can help find sources of financial assistance for environmental projects. All information and services are available at no charge. For more information, contact the OCAPP at (614) 644-3469 or (800) 329-7518, or your Ohio EPA district office.

 

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