450289002
     United States
     Environmental Protection
     Agency
Office of Air Quality
Planning And Standards
Research Triangle Park, NC 27711
August 198!?
     AIR
     LOCATING AND ESTIMATING
     AIR EMISSIONS
     FROM SOURCES OF
     CHROMIUM (SUPPLEMENT)
       Note:  The material herein on electroplating, chromic acid anodizing and
           cooling towers supersedes the material in EPA-450/4-84-007g.
MC-II

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                                            EPA-450/2-89-002
                                                 August 1989
  LOCATING AND ESTIMATING AIR EMISSIONS FROM

              SOURCES OF CHROMIUM
                  SUPPLEMENT
                      By

          Midwest  Research  Institute
                  Suite 350
         401 Harrison Oaks Boulevard
         Gary, North Carolina  27513

   EPA Project Officer:  Dallas W. Safriet
    U. S. Environmental Protection Agency
         Office of A1r and Radiation
Office of Air Quality  Planning  and  Standards
Research  Triangle Park, North Carolina  27711
                 August 1989

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This report has been reviewed by the Office of A1r Quality Planning And
Standards, U. S. Environmental Protection Agency, and approved for
publication.  Any mention of trade names or commercial products 1s not
Intended to constitute endorsement or recommendation for use.
                             EPA-450/2-89-002

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                             TABLE OF CONTENTS

                                                                       Page

LIST OF FIGURES	     ill

LIST OF TABLES	     111

SECTION 1.0  PURPOSE OF DOCUMENT	       1

SECTION 2.0  OVERVIEW OF DOCUMENT CONTENTS	       3

SECTION 3.0  CHROMIUM EMISSION SOURCES	       5

             3.1  CHROMIUM ELECTROPLATING AND CHROMIC ACID
                    ANODIZING OPERATIONS	       5
                  3.1.1  Background Information	       5
                  3.1.2  Uncontrolled Chromium Emissions	      17
                  3.1.3  Emission Reduction Techniques	      21
                  3,1.4  Nationwide Emission Estimates	      23

             3.2  COOLING TOWERS	...      26
                  3.2.1  Background Information	      26
                  3.2.2  Potential Emission Reduction Techniques...      29
                  3.2.3  Cooling Tower Emissions	      34
                  3.2.4  Nationwide Emissions Distribution by
                           Industry	      38

SECTION 4.0  SOURCE TEST-PROCEDURES..	      41

             4.1  CHROMIUM ELECTROPLATING	      41
             4.2  COOLING TOWERS	      41

SECTION 5.0  REFERENCES	      43

APPENDIX A.  ADDITIONAL CHROMIUM ELECTROPLATING EMISSION DATA
             OBTAINED AND EVALUATED DURING DEVELOPMENT OF THIS
             REPORT	    A-1
                                    ii

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                              LIST OF FIGURES

                                                                       Page

 Figure 1.   Flow diagram  for a typical  chromic acid anodizing
              process	     11

 Figure 2.   Internals  of  crossflow and  counterflow cooling towers...     30

 Figure 3.   Designs  of various drift eliminators.	     33

                               LIST OF  TABLES

                                                                       Page
 TABLE  1.    TYPICAL OPERATING PARAMETERS  FOR HARD CHROMIUM
               ELECTROPLATING	      7

 TABLE  2.    TYPICAL OPERATING PARAMETERS  FOR DECORATIVE  CHROMIUM
               PLATING	      9

 TABLE  3.    CHROMIC ACID/SULFURIC ACID  ETCH  SOLUTION	      9

 TABLE  4.    TYPICAL OPERATING PARAMETERS  FOR CHROMIC ACID
               ANODIZING	     13

 TABLE  5.    HEXAVALENT AND  TRIVALENT CHROMIUM DEPOSIT COM! OSITIONS       16

 TABLE  6.    UNCONTROLLED EMISSION  DATA  FOR TOTAL  AND HEXAVALENT
               CHROMIUM FROM CHROMIUM PLATING OPERATIONS	     18

 TABLE  7.    TANK PARAMETERS  AND PROCESS OPERATING PARAMETERS
               MONITORED DURING CHROMIUM PLATING TESTS	     20

 TABLE  8.    PERFORMANCE LEVELS OF  INDIVIDUAL CONTROL DEVICES	     24

 TABLE  9.    NATIONWIDE NUMBER OF OPERATIONS  AND ESTIMATED  HEXAVALENT
               CHROMIUM EMISSIONS FROM CHROMIUM ELECTROPLATING AND
               CHROMIC ACID ANODIZING OPERATIONS	      25

 TABLE  10.   MODEL COMFORT COOLING TOWERS AND  HOURLY BASELINE Cr+S
               EMISSIONS	      28

TABLE  11.   EMISSION FACTORS FOR HEXAVALENT  CHROMIUM FROM
              COOLING TOWERS	.	      36

TABLE  12.   NATIONWIDE COOLING TOWER CHROMIUM EMISSIONS SUMMARY....      40

TABLE A-l.   ADDITIONAL CHROMIUM ELECTROPLATING EMISSION DATA
              OBTAINED AND EVALUATED DURING DEVELOPMENT OF THIS
              REPORT	    A-l
                                    111

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                          1.0  PURPOSE OF DOCUMENT

       The U.  S. Environmental  Protection Agency (EPA), States, and local
 air pollution control  agencies are becoming Increasingly aware of the
 presence of substances 1n the  ambient air that may be toxic at certain
 concentrations.  This  awareness,  in turn, has led to attempts to identify
 source/receptor relationships  for these substances and to develop control
 programs to regulate emissions.   Unfortunately,  very little information is
 available on  the ambient  air concentrations of these substances or on the
 sources  that  may be discharging them to the atmosphere.
       To assist groups interested  in inventorying air emissions of various
 potentially toxic substances,  EPA  is preparing a series  of documents  that
 compiles available information on  the sources  and emissions of these
 substances.   This document was prepared as  a supplement  to a previous EPA
 document that addressed chromium emissions,  "Locating and  Estimating  Air
 Emissions  From Sources of Chromium,"  EPA-450/4-84-007g.  The supplement
 updates  technical  information  and  presents  new emission  data upon  which
 emission factors are based for chromium emissions  from cooling towers and
 chromium electroplating operations.   The  reader  should use both  the
 original  document and  this supplement  to  obtain  the most complete
 assessment  of emissions from these two  sources of  chromium emissions.   The
 information in this supplement was obtained  by EPA's  Emission  Standards
 Division  for  use in development of National  Emission Standards for a
 Hazardous Air Pollutant (NESHAP) for chromium used in electroplating
 operations and  for regulation of chromium emissions from comfort cooling
 towers under  the Toxic Substances Control Act.
      The reader  is strongly cautioned against using the emissions
 information contained in the original document or this supplement to
 develop an exact assessment of  emissions from any particular facility.
 Because of insufficient data, no estimate can be made of the error that
 could result when these factors are used to calculate emissions from any
given facility.  It is  possible,  in some extreme cases, that orders-of-
magnltude differences  could result between actual and calculated
emissions, depending  on differences in source configurations, control
equipment, and operating practices.  Thus, in situations  where an accurate

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assessment of chromium emissions 1s necessary, source-specific information
should be obtained to confirm the existence of particular emitting
operations, the types and effectiveness of control measures, and the
Impact of operating practices.  A source test and/or material balance
should be considered as the best means to determine air emissions directly
from an operation.
      Possible sources of plant-specific information that would be useful
in estimating air emissions of hexavalent chromium include the National
A1r Toxics Information Clearinghouse database maintained by EPA or the
Toxics Release Inventory (TRI) data resulting from Section 313 of the
Superfund Amendments and Reauthorization Act (SARA).  In the absence of
specific Information about the locations of facilities, State Departments
of Commerce, trade associations, or references such as the Thomas Register
of American Manufacturers may be sources of information.

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                     2.0  OVERVIEW OF DOCUMENT CONTENTS

       This  section  outlines the  information  presented in the remaining
 sections of this  report and indicates  whether the  information is new or
 whether It  is  a revision of Information  presented  in the original
 document.
       Section  3.1 presents  process  descriptions  for  five kinds of
 plating/anodizing operations.  New  information is  included  for decorative
 chromium electroplating of  plastics, chromic  acid  anodizing,  and trivalent
 chromium plating.   Additional process  information  is provided to
 supplement  the discussion of hard and  decorative chromium electroplating
 presented in the  original document.  New emission  data are  presented for
 hard and decorative chromium electroplating operations;  the results  of  an
 engineering mass  balance  to  obtain  an  emission estimate  for chromic  acid
 anodizing are also  presented.  A significant change  from the  original
 document is 1n the  format of the chromium emission factors  for hard  and
 decorative plating  operations, which have changed  from kilograms per hour
 per square foot of  tank area to milligrams per ampere-hour.   Supplemental
 Information has been Included on emission control  techniques  for' reduction
 of chromic add mist from plating operations.  New information 1s
 presented on nationwide chromium emission estimates"  for  three  types  of
 plating operations:  hard plating, decorative plating, and  chromic acid
 anodizing.
      Section 3.2 presents updated information about the distribution of
 industrial process cooling towers that use chromium-based water treatment
 chemicals  and presents new information about  comfort cooling towers.  New
 information also is presented on emission reduction techniques for
 chromium emissions from cooling towers.  New  emission data are presented
 for cooling towers equipped with low- and high-efficiency drift
 eliminators.  A significant change from the original  document  is in the
 format of  the chromium emission factor, which has changed from picograms
 per joule  of thermal energy input to the power plant associated with the
cooling tower to percentage of  the recirculating  chromium that is
emitted.   New information is presented  on nationwide  chromium emission
estimates  for industrial cooling  towers in  eight  industries.

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      Section 4.0 summarizes the procedures used for source sampling and
analysis of chromium 1n emission streams from electroplating operations
and cooling towers.

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                       3.0  CHROMIUM EMISSION SOURCES

 3.1  CHROMIUM ELECTROPLATING AND CHROMIC ACID ANODIZING OPERATIONS
 3.1.1  Background Information
       Plating and anodizing  operations range in size from small shops,
 with one  or two tanks that are  operated only a few hours per week, to
 large shops with several  tanks  that are operated 24 hours per day, 7 days
 per week.   Many plating and  anodizing  -operations are captive shops that
 perform chromium electroplating or  chromic acid anodizing as one operation
 within or for a manufacturing facility,  while others are job shops that
 provide custom plating or anodizing services for many different clients.
 Captive and job shops may perform hard or decorative chromium plating or
 chromic add anodizing or any combination of these three operations.
       The  estimated  number of electroplating shops nationwide is
 1,540 hard chromium  plating  facilities and 2,800 decorative  chromium
 plating facilities.    The estimated number of chromic acid anodizing shops
 nationwide is 680.    Electroplating and  anodizing shops  typically  are
 located 1n or near industrial centers  1n areas  of high population
 density.   States  with large  numbers  of chromium electroplaters  include
 California,  Illinois,  Massachusetts, Michigan,  New York,  Ohio,  and
 Pennsylvania.
       3.1.1.1   Hard  Chromium  Electroplating  of  Metals.   In hard  plating,  a
 relatively  thick  layer of chromium  is  deposited directly  on the  base  metal
 (usually steel) to provide a surface with wear  resistance, a  low
 coefficient  of  friction,  hardness, and corrosion resistance, or to build
 up surfaces  that  have been eroded by use.    Hard plating  is used for  items
 such as hydraulic cylinders  and  rods,  industrial rolls, zinc die castings,
 plastic molds,  engine components, and marine hardware.
      Tanks  used for hard  chromium electroplating usually are constructed
 of steel and  lined with a  polyvinyl  chloride sheet or plastisbl.  The
 anodes, which are Insoluble,  are made of a lead alloy that contains either
tin or antimony.  The substrate  to be plated, the cathode, is suspended
from a plating rack that  is connected to the cathode bar of the
rectifier.  The plating rack  may be  loaded in the tank manually, by a
hoist, or  by an automatically controlled hoist system.

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      The plating  tanks typically are equipped with  some  type of heat
exchanger.  Mechanical agitators or compressed air supplied through pipes
on the tank bottom provide uniformity of bath temperature and
composition.  Chromium electroplating requires constant control of the
plating bath temperature, current density, plating time,  and bath
composition.
      Hexavalent chromium plating baths are the most widely used baths to
deposit chromium on metal.  Hexavalent chromium baths are composed of
chromic add, sulfurlc add, and water.  The chromic add 1s the source of
the hexavalent chromium that reacts and deposits on the metal and that is
emitted to the atmosphere.  The sulfurlc add 1n the bath catalyzes the
chromium deposition reactions.  Typical operating parameters are given in
Table I.1*
      The evolution of hydrogen gas from chemical reactions at the cathode
consumes 30 to 90  percent of the power supplied to the plating bath,
leaving the remaining 10 to 20 percent for the deposition reaction.  When
the hydrogen gas evolves, 1t entrains chromic add and causes misting at
the surface of the plating bath.
      3,1.1.2  Decorative Chromium Electroplating of Metals.  In decorative
plating, the base material (e.g., brass, steel, aluminum,  or plastic)
generally 1s plated with a layer of nickel  followed by a relatively thin
layer of chromium to provide a bright surface with wear and  tarnish
resistance.   Decorative plating 1s used for Items such as  automotive trim,
metal furniture, bicycles, hand tools,  and  plumbing fixtures.   The  purpose
of decorative chromium plating is to achieve a combination of  the
following surface properties:
      1.  Blue-white color;
      2.  High reflectivity;
      3.  Tarnish resistance;
      4.  Corrosion resistance;
      5.  Wear resistance; and
      6.  Scratch resistance.
      Decorative electroplating baths operate  on  the  same  principle  as
that described for the hard chromium plating process:  the metal substrate
is immersed  in a plating  solution,  and  direct  current  is passed  from the

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  TABLE 1.   TYPICAL OPERATING PARAMETERS FOR HARD CHROMIUM ELECTROPLATING


Plating thickness, ym (mil)                              1.3-762 (0.05-30)

Plating time, mina                                               20-2,160

Chromic add concentration, g/a (oz/gal )b                  225-375 (30-50)

Temperature of solution, °C (°F)                           49-66 (120-150)

Voltage, volts                                                          c

Current, amperes (A)                                                    d

Current density, A/m2 (A/ft2)6                                1,600-6,500
                                                                 (150-600)
      * minutes.
     - grams per liter, oz/gal  « ounces per gallon.
 Depends on the distance between the anodes and the Items being plated.
 Dep^nds on the amount of surface area plated.
 A/m  = amperes per square meter (-square foot) of surface area plated.

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anode through the plating solution causing the desired metal  (copper,
nickel, chromium) to deposit out of the solution onto the metal  substrate
(cathode).
      Decorative chromium plating requires shorter plating times  and
operates at lower current densities than does hard chromium plating to
achieve the desired properties of the chromium plate.  Some decorative
chromium plating operations use fluoride catalysts instead of sulfuric
add because fluoride catalysts, such as fluosillcate or fluoborate, have
been found to produce higher bath efficiencies.8  Typical operating
parameters are shown in Table 2.
      3.1.1.3  Decorative Chromium Electroplating of Plastics.  Most plastics
that are electroplated with chromium are formed from the polymer  composed
of acrylonitrlle, butadiene, and styrene (ABS).8  The process for chromium
electroplating of ABS plastics consists of the following steps:
      1.  Chromic acid/sulfuric acid etch;
      2.  Dilute hydrochloric add dip;
      3.  Colloidal palladium activation;
      4.  Dilute hydrochloric acid dip;
      5.  Electroless nickel- plating or copper plating;  and
      6.  Chromium electroplating cycle.
      After each process step, the plastic 1s rinsed with water to prevent
carry-over of solution from one bath to another.   The chromic acid/
sulfuric acid etch solution (see Table 3)  renders the ABS surface
hydrophlHc and modifies the surface to provide adhesion for the metal
coating.9  The dilute hydrochloric acid dips  are used to clean the surface
and remove palladium metal  from the plating rack, which  is Insulated with
a coating of polyvinyl  chloride.   The colloidal  palladium activation
solution deposits a thin layer of metallic palladium over the plastic
surface.10  The metallic palladium induces the deposition of copper or
nickel,  which will  not  deposit directly onto  plastic.  The electroless
nickel  and copper plate are applied to impart electrical  conductivity to
the part; otherwise,  the insulating surface of the plastic could not be
electroplated with  chromium.   The electroless nickel  plating or  copper
electroplating baths  develop  a film on the plastic about  1.0 micrometer
(pin)  (3.9xlO"s inch [1n.])  thick.   The plating time  for electroless  nickel

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  TABLE 2.  TYPICAL OPERATING PARAMETERS FOR DECORATIVE CHROMIUM  PLATING
Plating thickness, utn (mil)                         0.003-2.5 (0.0001-0.1)
Plating time, min                                                   0.5-5
Chromic add concentration, g/i (oz/gal)                   225-375 (30-50)
Temperature of solution, °C (°F)                           38-46  (100-115)
Voltage, volts                                                           a
Current, A                                                               b
Current density, A/m2 (A/ft2)c                          540-2,400 (50-220)
^Depends on the distance between the anodes and the items  being plated.
DDepends on the amount of surface area being plated.
GAmperes per square meter (square foot) of  surface area plated.
            TABLE 3.  CHROMIC ACID/SULFURIC ACID ETCH SOLUTION
      Concentrated sulfurlc  add,  g/4 (oz/gal)               172 (23)
      Chromic acid,  g/a  (oz/gal)                             430 (57)
      Temperature, 8C  (°F)                            60-65  (140-149)
      Immersion time,  min                                       3-10

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 plating  and  electroless copper  plating  ranges  from 10 to 15 minutes  and  15
 to  30 minutes,  respectively,  at temperatures ranging from 25°  to  35°C  (77°
 to  95°F).  The  components of  the plating  baths Include the metal  salt
 (nickel  or copper),  a reducing  agent, a complexing agent,  a stabilizer,
 and a pH buffer system.    The  electroplating  of plastics  follows the  same
 cycle as that described for decorative  chromium electroplating.
      3.1.1.4   Chromic Add Anodizing.  Chromic acid anodizing  1s used primarily
 on  aircraft  parts  and architectural  structures that are subject to high
 stress and corrosion.  Chromic  acid  anodizing  is used to provide  an  oxide
 layer on aluminum  that imparts  the following properties:
      1.  Corrosion  protection;
      2.  Electrical  insulation;
      3.  Ease  of  coloring; and
      4.  Improved dielectric strength.
 Figure 1 presents  a  flow diagram for a  typical  chromic  add anodizing
 process.
      There  are four  primary differences between  the  equipment used for
 chromium electroplating and that used for chromic  add  anodizing:
 (a) chromic  acid anodizing requires the rectifier  to  be fitted with a
 rheostat or  other control mechanism to permit  starting  at about 5 V,
 (b) the tank is the cathode in the electrical  circuit,  (c) the aluminum
 substrate acts as the anode, and  (d) sldewall  shields typically are used
 instead of a liner in the tank to minimize short circuits and  to decrease
 the effective cathode area.   Types of shield materials used  are
 hercullte glass, wire safety glass, neoprene, and vinyl chloride
 polymers.
      The following pretreatment steps typically are used to clean the
 aluminum before anodizing:
      1.   Alkaline soak;
      2.   Desmut;
      3.   Etching; and
      4.   Vapor degreaslng.
The pretreatment steps used for  a particular aluminum substrate depend
upon the  amount of smut and the  composition  of  the aluminum.   The  aluminum
substrate is  rinsed between pretreatment steps  to remove cleaners.
                                    10

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              SUBSTRATE  TO BE PLATED
                PRETREATMENT STEPS

                Alkaline soak
                D«smut
                Etching
                Vapor degreaaing
                           RINSE
             CHROMIC ACID ANODIZING
                           RINSE
                      SEALING
                  FINAL PRODUCT
CHROMIC ACID
  EMISSIONS
Figure 1.  Flow diagram for a typical chromic acid  anodizing process
                                  11

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      The alkaline soak  is the  primary  preparatory step  In  cleaning  the
 aluminum; Its purpose  1s to dislodge  soil from the aluminum surface.   The
 solutions for alkaline cleaning are typically made up of compounds such  as
 sodium carbonate, sodium phosphate, and sodium hydroxide and usually
 contain a small amount of silicate to prevent metal attack.    The
 alkaline soak consists of Immersing the metal 1n the alkaline  solution
 that 1s mildly agitated with air.
      The purpose of desmuttlng 1s to remove soil or grease films that
 cleaners and etchants leave behind.  Desmuttlng baths typically consist  of
 a cold nitric acid solution mixed with water at a concentration ranging
 from 5 to 50 percent acid by volume.  The nitric add bath also 1s used
 either as a bleaching treatment to remove dyes from faulty coatings or as
 part of the technique of producing multicolor coatings.    Other
 desmuttlng treatments use combinations of chromic, phosphoric, and
 sulfuric adds depending upon the amount of smut to be removed or the
 aluminum composition.
      When a dull finish 1s desired, the aluminum 1s etched before
 anodizing.  Etching baths consist of a dilute solution of soda ash,
 caustic soda, or nitric add.18  The degree of etching desired and the
 composition of the aluminum being treated determine the concentration of
 the etch solution, temperature  of the bath, and duration of the etch.
      The vapor degreaslng step removes any residual  oil or grease on the
 surface of the aluminum prior to the anodizing operation.
      Typical operating parameters for chromic add anodizing baths are
 presented in Table 4*19*20  The voltage 1s applied step-wise (5 V per
minute) from 0 to 40 V and maintained at 40 V for the remainder of the
 anodizing time.   A low starting voltage (i.e.,  5  V) minimizes current
 surge that may cause "burning"  at contact points  between the rack and the
aluminum part.  The process  Is  effective over a wide  range  of voltages,
temperatures, and anodizing  times.  All  other factors  being equal,  high
voltages tend to produce bright, transparent films,  and  lower voltages tend
to produce opaque films.     Raising the bath temperature increases  current
density to produce thicker films 1n a given time  period.  Temperatures up
to 498C (120°F)  typically are used to  produce films that are to be  colored
by dyeing.     The amount  of  current varies depending on  the  size  of the
                                    12

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      TABLE 4.  TYPICAL OPERATING  PARAMETERS FOR CHROMIC
                        ACID ANODIZING
Chromic add concentration, g/*, (oz/gal)    50-100 (6.67-13.3)
Temperature, *C (°F)                             32-35 (90-95)
Plating time, min                                       30-60
pH                                                   0.5-0.85
Current density, A/m2 (A/ft2)a           1,550-7,750 (144-720)
Voltage (step-wise), volts                              30-40
Film thickness, ym (mil)                   0.5-1.27 (0.02-0.05)
aAmperes per square meter (square foot)  of surface area
 plated.
                              13

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aluminum parts;  however, the current density typically ranges from  1,550
to 7,750 A/m2  (144 to 720 A/ft2).
      The postanodizlng steps include sealing and air drying.  Sealing
causes hydratlon of the aluminum oxide and fills the pores in the aluminum
surface.  As a result, the elasticity of the oxide film increases,  but the
hardness and wear resistance decrease.    Sealing is performed by
immersing aluminum in a water bath at 88° to 99°C (190° to 210°F) for a
minimum of  15  minutes.    Chromic add or other chromates may be added to
the solution to  help improve corrosion resistance.  The aluminum is
allowed to  air dry after it is sealed.
      3.1.1.5  Trtvalent Chromium Plating.  Trlvalent chromium
electroplating baths have been developed primarily to replace decorative
hexavalent  chromium plating baths.  Development of a trivalent bath has
proven to be difficult because trivalent chromium solvates in water to
form complex stable ions that do not readily release chromium.  The
trivalent chromium baths that have been developed are proprietary baths.
      There are  two types of trivalent chromium processes on the market:
single-cell and  double-cell.  The major differences 1n the two processes
are that (1) the double-cell process solution contains m1nimal-to-no
chlorides whereas the single-cell process solution contains a high
concentration  of chlorides; and (2) the double-cell  process utilizes lead
anodes that are  placed in anode boxes that contain a dilute sulfuric add
solution and are lined with a permeable membrane whereas the single-cell
process utilizes carbon or graphite anodes that are  placed in direct
contact with the plating solution.25
      The advantages of the trivalent chromium processes over the
hexavalent chromium process are (1) fewer environmental  concerns,
(2) higher productivity, and (3)  lower operating costs.   In the  trivalent
chromium process, hexavalent chromium 1s a plating bath  contaminant.  .
Therefore,  the bath does not contain any appreciable amount of hexavalent
chromium, which  is more toxic than trivalent chromium.   The total chromium
concentration of trivalent chromium solutions 1s approximately one-fifth
that of hexavalent chromium solutions.     As a result  of  the  chemistry of
the trivalent chromium electrolyte, misting  does not occur during plating,
as it does during hexavalent chromium plating.   Use  of trivalent  chromium
                                    14

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 also reduces  waste disposal  problems and costs.  Waste treatment of
 hexavalent  chromium is a two-stage process.   The hexavalent chromium is
 first reduced to  the trivalent chromium ion;  then it can be precipitated
 as  chromium hydroxide.  Trivalent chromium plating solution wastewaters
 are already in the reduced trivalent state and require only the chromium
 hydroxide precipitation step.
       Productivity is increased when trivalent chromium processes are used
 because  less  stripping and replating of parts are required, more parts can
 be  placed on  a rack,  and more  racks  can be placed on a workbar.
       The cost of operating  a  trivalent chromium process is less than that
 of  a hexavalent chromium process because of the lower wastewater treatment
 costs and lower operating costs due  to  a reduction in rejects  and high
 productivity.
       The disadvantages of the trivalent chromium process  are  that the
 process  is  more sensitive to contamination than the  hexavalent chromium
 process  and the trivalent chromium process cannot plate  the full  range of
 plate thicknesses  that the hexavalent chromium process can.29   Because it
 is  sensitive  to contamination,  the trivalent  chromium process  requires
 more  thorough  rinsing  and  tighter laboratory  control  than  the  hexavalent
 chromium process.  Trivalent chromium baths can  plate thicknesses  ranging
 up to 0.13 to  25 micrometers (urn) (0.005 to 1.0  mils).28   The  hexavalent
 chromium process can plate thicknesses up  to  762  pm  (30 mils).  Therefore,
 trivalent chromium solutions cannot be used for most  hard  chromium plating
 applications.
      The plating efficiency of a trivalent chromium bath, approximately
 20 to 25 percent, is slightly higher than that of a hexavalent chromium
 plating bath.     The color, hardness, and corrosion resistance of triva-
 lent chromium deposits are comparable to those of hexavalent chromium
deposits.    However, the composition of the trivalent chromium deposit is
 significantly different than that of the hexavalent chromium deposit.
Table 5 presents the composition of trivalent  and hexavalent chromium
     1*.  3l
deposits.
                                    15

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     TABLE 5.  HEXAVALENT AND TRIVALENT  CHROMIUM DEPOSIT COMPOSITIONS
Chromium deposit     Carbon,  % wt       Oxygen, % wt       Chromium, % wt
Hexavalent                0.0               0.4                99+
TMvalent                 2.9               1.6                95+
                                   16

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 3.1.2  Uncontrolled  Chromium Emissions
       Emissions of chromic  acid mist from the electrodeposition of
 chromium from chromic  acid  plating baths occur because of the inefficiency
 of the hexavalent chromium  plating process;  only about 10 to 20 percent of
 the current  applied  actually is used to deposit chromium on the Item
 plated.   Eighty to ninety percent  of the current applied is consumed by
 the evolution of hydrogen gas at the cathode with the  resultant, liberation
 of gas bubbles. Additional  bubbles  are formed at the  anode due to the
 evolution of oxygen.   As the bubbles burst at the surface of the plating
 solution, a  fine mist  of chromic acid droplets is formed.
       3.1.2.1  Hard  Chromium and Decorative  Electroplating Operations.
 Uncontrolled emission  data  for 10  hard chromium plating  operations and
 2  decorative chromium  plating  operations are presented  in  Table 6.   These
 data were obtained from 11  EPA tests and 1 non-EPA test.   Table 7 presents
 tank parameters and  process  operating parameters  monitored during each  of
 the 12 tests.   The process  parameters monitored during testing  include
 current  supplied to  the plating  baths,  voltage, chromic  acid  concentration,
 and temperature of the plating  baths.   The chromic add  concentration and
 temperature  did not vary significantly  within  each type  operation  for the
 emission  tests  and appeared to be representative of typical operating
 values for conventional hard and decorative chromium plating operations.
 The amount of current supplied during testing  varied considerably  because
 of  the different types and quantities of parts plated.
       Based  on  the existing test data,  an  uncontrolled emission factor of
 10  milligrams of hexavalent chromium per ampere-hour (mg/Ah)  (0.15 grain
 per ampere-hour [gr/Ah]) 1s considered  to be representative of uncon-
 trolled emissions from a hard chromium electroplating operation, and an
 uncontrolled hexavalent chromium emission factor of 2 mg/Ah (0.03 gr/Ah)
 1s  considered representative of uncontrolled emissions  from a decorative
 chromium electroplating operation.
      The emission  factor for uncontrolled chromium emissions from
decorative chromium plating  operations is based on EPA-approved  test data
from two plants whose tanks  represent the extremes in tank size  for
decorative chromium plating.  Although the sizes of these tanks  may not be
                                    17

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                        TABLE 6.  UNCONTROLLED EMISSION  DATA FOR TOTAL AND HEXAVALENT CHROMIUM  FROM
                                               CHROMIUM  PLATING OPERATIONS*
CO
Process conditions
Plant
Hard chroaiiM plating
Plant Ab'32
Plant Bc'33
Plant Cd'34
Plant Dc'35
Plant E0'36
Plant Ff'37
Plant G*'38
Plant Hc»39
Plant I1'40
Plant Jc»41
Average
Total tank
No. of surface area,
tanks «2 (ft2)
1 5.8
(63)
2 2.5
(27)
4 8.4
(90)
1 5.2
(56)
1 3.4
(37)
1 1.8
(20)
1 1.4
(1.5)
1 5.5
(60)
2 9.0
(99)
3 6.6
(71)

Aapere-
hours
14,000
14.400
20,000
19,800
11,700
12,200
8,900
3,440
8,530
8,790

Actual
gas flow
rate,
(ft3/«in)
226
(7,970)
152
(5,390)
339
(12,000)
177
(6,260)
190
(6,670)
126
(4,540)
95
(3,360)
242
(8,540)
290
(10,300)
512
(18,100)

Mass en 1 ss ion
rate, kg/h (Ib/h)
Total Cr
0.029
(0.064)
0.008
(0.018)
e
0.076
(0.167)
e
e
e
0.009
(0.019)
0.100
(0.221)
0.044
(0.097)

Cr*°
0.026
(0.057)
0.015
(0.033)
0.039
(0.085)
0.076
(0.168)
0.031
(0.069)
0.083
(0.183)
0.024
(0.053)
g
g
0.090
(0.199)
0.046
(0.102)

Process Cr emission
rate, «g/A-h (gr/A-h)
4.0 (0.06)
3.2 (0.05)
4.6 (0.07)
9.1 (0.14)
6.3 (0.10)
16.3 (0.25)
6.5 (0.10)
3.6 (0.06)h
22.5 (0.35)
15.5 (0.24)

9.6 (0.15)
                                                                                                           (continued)

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                                                   TABLE  6.   (continued)
Actual
Process conditions gas flow
Plant
Total tank
No. of surface area,
tanks m2 (ft2)
rate,
Ampere- « /m I n
Mass emission
rate, kg/h (Ib/h)
hours (ft3/min) Total Cr Cr*°
Process Cr*6 emission
rate, mg/A«h (gr/A'h)
Decorative chromium plating
Plant Kc»42
Plant Lc'43
Average
1 22.6
(240)
1 2.9
(30.8)
97,000 683
(24,100)
6,500 70
(2,470)
e 0,066
(0.145)
e 0.004
(0.008)
2.0 (0.03)
1.3 (0.02)
1.6 (0.02)
 All tests were performed by EPA  except  for  the Plant H test which was performed by the Naval Energy and Environmental  Support
.Activity, Port Hueneme, California.
 Ampere-hour and mass emission rate values are based on an average of four test runs.
 Ampere-hour and mass emission rate values are based on an average of three test runs.
 Ampere-hour and mass emission rate values are based on an average of six test runs.
TTotal chromium emissions were not determined.
 Ampere-hour and mass emission rate values are based on an average of five test runs.
PHexavalent chromium emissions were not  reported.
.Not included in average value because data  are based on total chromium.
 Ampere-hour and mass emission rate values are based on an average of 11 test runs.

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             TABLE 7.   TANK PARAMETERS  AND PROCESS OPERATING PARAMETERS MONITORED DURING CHROMIUM PLATING TESTS
ro
o
Average process parameters monitored
Tank parameters


Plant
Hard chromium plating
Plant A32
Plant B33
Plant C34
Plant D35
Plant E36
Plant F37
Plant G38
Plant H39
Plant I40
Plant J41
Decorative chromium plating
Plant K42
Plant L43

Ho. of
tank(s)

1
2
4
1
1
1
1
1
2
3

1
1
Total tank
surface area.
•2 mV

5.8 (63)
2.5 (27)
8.4 (90)
5.2 (56)
3.4 (37)
1.8 (20)
1.4 (15)
5.5 (60)
9.0 (99)
6.6 (71)

22.6 (240)
2.9 (31)
Total tank
capac i ty ,
I (gal)b

10,710 (2,830)
4,130 (1,090)
35,000 (9,250)
15,820 (4,180)
9,270 (2,450)
4,810 (1,270)
5,720 (1,510)
7,190 (1,900)
11,210 (2,960)
6,090 (1,610)

61,170 (16,160)
3,860 (1,020)

Current ,
amperes

6,220
1,610
2,660
8,390
4,970
2,640
3,480
2,480
1,140
1,150

21,320
2,700

Voltage,
volts

9.0
12.3
7.9
7.4
7.0
4.9
4.9
6.6
7.7
6.1

22.4
5.1
Chromic
acid
concen-
tration.
3/1
(oz/gal)

254 (34)
208 (28)
250 (33)
156 (21)
250 (33)
210 (28)
210 (28)
210 (28)
225 (30)
173 (23)

300 (40)
241 (32)

Bath
temp..
•C CF)

52 (125)
62 (145)
54 (130)
52 (125)
54 (130)
56 (133)
55 (131)
60 (140)
59 (138)
49 (120)

54 (130)
48 (119)
           m  = square meters, ft  = square feet.

           al = liters, gal = gallons.

-------
 typical  of the sizes of other decorative plating tanks, there is
 insufficient evidence to show that emissions are directly proportional to
 tank  size.  In any case, the uncontrolled emissions have been normalized
 to account for tank size using the ampere-hours term in the emission
 factor.   Because the data are limited,  a conservative approach was taken
 in selecting the emission factor  for decorative plating.   Thus,  a value of
 2  mg/Ah  was selected instead of the average  value for the two tests.
       3.1.2.2  Chromic Acid  Anodizing Operations.  Uncontrolled  emission
 data  for chromic acid anodizing operations were not obtained through  an
 EPA source test at an anodizing facility.  Instead, an estimate  of the
 amount of hexavalent chromium emissions  was  made by performing a mass
 balance  on a scrubber used to control emissions from a chromic acid
 anodizing operation.   Outlet scrubber water  grab samples  were analyzed to
 determine the amount  of  hexavalent  chromium  in  the  sample,  and a mass
 balance  was performed on the scrubber to determine  the inlet hexavalent
 chromium emission  rate.   The results of  this mass balance indicate that an
 uncontrolled of emission factor of  6.0xlO~   kilogram of hexavalent
 chromium per hour  per square meter  of tank surface  area (1.2x10"  pound
 per hour per square foot of  tank surface area)  1s appropriate to
 characterize emissions from  chromic add anodizing.    Alternatively,  if
 the tank  surface area  is  unknown, uncontrolled  emission rates can  be  used
 to approximate  the  level  of  uncontrolled chromium emissions.  The  results
 of the mass  balance at the small anodizing operation  (tank capacity
 -1,900 liters  [500  gallons!)  and results from a  non-EPA emission test at a
 large chromic acid  anodizing operation (tank capacity -17,600 liters
 [4,600 gallons]) indicate uncontrolled emission rates range from 0.0012 to
 0.0028 kg/h  (0.0026 to 0.0062 Ib/h), respectively/4  At this time, there
 are insufficient data from anodizing operations to determine conclusively
 that one emission factor format is more  appropriate than the other.
 3.1.3  Emission Reduction Techniques
      The principal techniques used to control  emissions of chromic acid
mist from decorative and hard chromium plating  and chromic acid anodizing
operations include add-on control  devices and chemical fume
suppressants.  The control devices most  frequently used are mist
eliminators and wet scrubbers that are operated  at relatively low pressure
                                    21

-------
drops.  Because of the corrosive properties of chromic acid, control
devices typically are made of polyvinyl chloride (PVC) or fiberglass.
      Chemical fume suppressants are added to decorative chromium plating
and chromic acid anodizing baths to reduce chromic add mist.  Although
chemical agents alone are effective control techniques, many plants use
them 1n conjunction with a control device.
      Chevron-blade and mesh-pad mist eliminators are the types of mist
eliminators most frequently used to control chromic add mist.  The most
Important mechanism by which mist eliminators remove chromic acid droplets
from gas streams 1s the 1nert1al 1mpact1on of droplets onto a stationary
set of blades or a mesh pad.  M1st eliminators typically are operated as
dry units that are periodically washed down with water to clean the
Impaction media.
      The wet scrubbers typically used to control emissions of chromic
acid mist from chromium plating and chromic acid anodizing operations are
single and double packed-bed scrubbers.  Other scrubber types used less
frequently include fan-separator packed-bed and centrifugal-flow
scrubbers.  Scrubbers remove chromic add droplets  from.the gas stream by
humidifying the gas stream to increase the mass of  the droplet particles,
which are then removed by Impingement on a packed bed.  Once-through water
or redrculated water typically Is used as the scrubbing liquid because
chromic add 1s highly soluble 1n water.
      Chemical fume suppressants are surface-active compounds that are
added directly to chromium plating and chromic add anodizing baths  to
reduce or control  misting.   Fume suppressants  are classified as temporary
or as permanent.  Temporary fume suppressants  are depleted  mainly  by the
decomposition of the fume suppressant and dragout of  the plating solution,
and permanent fume suppressant are depleted mainly  by dragout of the
plating solution.   Fume suppressants,  which are manufactured 1n liquid,
powder, or tablet form, include wetting agents that reduce  misting by
lowering the surface tension of the plating or anodizing  bath,  foam
blankets that entrap chromic acid mist at the  surface of  the plating
solution,  or combinations of both a wetting agent and foam  blanket.
                                    22

-------
       The performance capabilities of the control devices used to control
 chromic acid mist are presented in Table 8.  The air pollution control
 devices tested include four mist eliminators, three packed-bed scrubbers,
 and one packed-bed scrubber in conjunction with a mist eliminator used to
 control emissions from hard chromium plating operations.  In addition, one
 emission test was conducted at a decorative chromium plating facility to
 determine the performance of chemical fume suppressants in controlling
 chromic acid mist.
       The average hexavalent chromium removal efficiency of mist
 eliminators was 98 percent for nrist eliminators with double sets of
 blades, 90 percent for mist eliminators with single sets of blades, and
 98 percent for mesh pad units.  The average hexavalant chromium removal
 efficiency of scrubbers was 98 percent.   The hexavalant chromium removal
 efficiency of the scrubber in conjunction with the mist eliminator was
 95 percent.
       For decorative chromium plating operations,  the performance
 efficiency of both chemical  fume suppressants tested (a foam blanket and  a
 combination of a foam blanket and wetting agent) was greater than
 99 percent.  This  performance efficiency is  achievable  as  long  as vendor
 recommendations  on the makeup and use of the fume  suppressants  are
 followed  rigorously.
 3.1.4   Nationwide  Emission  Estimates
       Table 9  presents the estimated  number  of operations and the
 nationwide  annual  emission rate  for each  type of operation.  The
 assumptions  regarding  the existing control levels for each type operation
 were derived from data obtained  during the development of the NESHAP for
 chromium  electroplating operations.  The nationwide emission rate for hard
 chromium  electroplating operations was based on the assumption that
 30 percent of operations are uncontrolled, 30 percent of operations are
 controlled by mist eliminators with single sets of blades (90 percent
 efficient), and 40 percent are controlled by single packed-bed scrubbers
 (97 percent efficient).  The nationwide emission rate for decorative
chromium electroplating operations was based on the assumption that
 15 percent of operations are uncontrolled, 80 percent are controlled by
chemical fume suppressants (97 percent efficient),  and 5 percent are
                                    23

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                                               TABLE  8.   PERFORMANCE  LEVELS  OF  INDIVIDUAL  CONTROL  DEVICES
            Plant  Plant
            cade   name
Description of control device
 Ho.  of
  runs
averaged
                                                                              Concen-
                                                                            tration, mo/ ds cm
                                                                            Inlet     Outlet
                                                                                                                            Hass Mission
                                                                                                                              rate, ka/h
Inlet
          Outlet
Efficiency.
 percent*
                                   Process emission
                                     rate. jo,/Ah
                                   Inlet
                                             Outlet
ro
            HARD CHROMIUM HATING

            Chevron-blade mist eliminators
A
B
D
Single set of overlapptng-type blades
Single set of overlapping type blades
Double set of overlapping type blades
4
3
3
2.030
1.760
7.690
0.306
0.149
0.124
0.0260
0.01 51
0.0763
0.0033
0.0013
0.0012
fi7.9
91.3
98.4
3.96
3.16
9.06
0.65
0.27
0.15
Mesh-pad mist eliminators
F
a
t?
Ec
Packed -bed
I
J
C

DECORATIVE
Two mesh pads In series
Iwo mesh pads in series
One aesh pad
Two sets of chevron -blades followed by two aesh pads
scrubbers
Single packed-bed scrubber
Double packed-bed scrubber
Double packed-bed scrubber followed by chevron-blade list
eliminator with * double set of wave-type blades
CHROMIUM PLATING
S
3
3
3

11
3
6


11.400
4.410
0.609
3.070

5.510
1.670
2.040


0.0326
0.0435
0.0257
0.040

0.0302
0.0523
0.081


0.0829
0.0241
0.0087
0.0313

0.0900
0.0464
0.0388


0.0002
0.0003
O.OOOS
0.0004

0.0005
0.0015
0.0015


99.7
98.9
94.5
98.7

99.4
96.2,
95. 4d


16.3
6.52
3.60
6.33

22.5
15.5
4.57


0.04
0.07
0.18
0.08

0.14
0.56
0.14


Fume suppressants
L

1. Foam blanket
2. Foaa blanket In combination with wetting agent
3
3
0.916
0.916
0.0041
0.0021
0.0036
0.0036
0.00002
0.00001
*99.5
*99.8
1.34
1.34
0.006
0.003
            Efficiencies are based on the average of efficiencies from each run.  Therefore, they My not agree with the  values obtained by calculating the efficiency from the average
            .Inlet and outlet rate.
            "Results are for total chromium.   Hexavalent chromium analyses were not performed.
            CA aolsture extractor preceded the mist eliminator unit.  However, the eaissio* data for the combined control  techniques were attributed to the mist eliminator unit only.
             Any droplets caught by the aoisture extractdr would have been collected by the altt eliminator  unit, if the aoisture extractor was eliminated fro* the systea.
            "The efficiency presented is the  combined efficiency of both units.

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          TABLE 9.  NATIONWIDE NUMBER OF OPERATIONS AND ESTIMATED
        HEXAVALENT  CHROMIUM EMISSIONS FROM CHROMIUM ELECTROPLATING
                  AND  CHROMIC ACID ANODIZING OPERATIONS
Operation
No. of plants
  nationwide
   f*jat1onwide
Cr+  emissions,
      (tons/yr)
Hard chromium plating
Decorative chromium plating
                      2
Chromic acid anodizing
    1,540

    2,800

     630
   145  (160)

     10  (11)

   3.6  (3.9)
                                    25

-------
controlled by  single packed-bed  scrubbers  (95  percent  efficient).   The
nationwide annual emission rate  for chromic  acid  anodizing  operations  was
based on the assumption that 40  percent of operations  are uncontrolled,
10 percent are controlled by mist eliminators  with  single sets  of  blades
(90 percent efficient), 30 percent are controlled by chemical fume
suppressants (97 percent efficient), and 20  percent are  controlled by
single packed-bed scrubbers (95  percent efficient).
3.2  COOLING TOWERS
3.2.1  Background Information
      Cooling  towers are devices that cool warm water  by contacting  1t
with ambient air that is drawn or forced through  the tower.  This  cool
water is used  to remove heat from a process  or an HVAC chiller  and 1s  then
redrculated to the cooling tower.  Chemicals  are added  to  this
recirculatlng  water to Inhibit heat exchanger  corrosion.  One of the many
classes of corrosion Inhibitors used is chromium  based.   Air emissions of
chromium occur when water droplets (and the  chemicals  they  contain)
entrained in the air stream that 1s drawn through the  tower are emitted  to
the atmosphere.  These droplet emissions are referred  to  as "drift."  .All
cooling towers that are used to remove heat from  an Industrial process or
chemical reaction are referred to as industrial process cooling towers
(IPCT's).  Towers that are used to cool heating,  ventilation, and  air
conditioning (HVAC) and refrigeration systems are referred to as comfort
cooling towers (CCT's).
      3.2.1.1  Industrial  Process Cooling Towers.   Major users of  IPCT's
that also use  chromium-based water treatment chemicals are chemical
manufacturing  plants, petroleum refineries, and primary metals
facilities.  Several miscellaneous manufacturing industries (textiles,
tobacco products, tire and rubber products, and glass  products)  and
utilities use chromium-based water treatment chemicals to a lesser
degree.  It is estimated that IPCT's  are used at approximately 190 petro-
leum refineries,  1,800 chemical  manufacturing plants,  240 primary metals
plants, and 730 plants in  the  miscellaneous Industries/5  In addition,
the percentage of cooling  towers using  chromium-based  water treatment
chemicals 1n each industry is  estimated as  70 percent  at  petroleum
refineries, 40 percent at  chemical  manufacturing plants,  20  percent at
                                    26

-------
 primary metals facilities, 15 percent at plants in the tire and rubber
 Industry,  and 5 percent at plants in the other miscellaneous industries.
 In the utilities Industry, it was reported that chromium-based water
 treatment  chemicals are used at two electric power plants.    When
 combined with data from plant responses to EPA information requests in
 each of these industries,  these estimates result in a total of about
 2,855 IPCT's using chromium-based water treatment chemicals:  476 at
 petroleum  refineries,  2,039 at chemical plants,  224 at primary metals
 plants, 110  at miscellaneous plants, and 6 at utilities.   The nationwide
 baseline Cr*  emissions from these towers are estimated to be 85 megagrams
 per year (Mg/yr)  (94 tons  per year [tons/yr]).
       3.2.1.2  Comfort Cooling Towers.   Comfort  cooling towers are used in
 all  States 1n the U.S.,  primarily in urban areas.   Major  users of CCT's
 with HVAC  systems Include  hospitals, hotels,  educational  facilities,
 office buildings,  and  shopping malls.   Refrigeration  systems that may
 operate with CCT's include 1ce skating  rinks, cold  storage (food)  ware-
 houses,  and  other commercial  operations.   The EPA estimates that the
 nationwide population  of CCT's 1s 250,000 units  and that  15 percent of
 CCT's (about 37,500) use chromium-based water treatment chemicals.  These
 CCT's are  estimated  to emit  between  7.2 and 206  Mg/yr  (8  to 227  tons/yr)
 of chromium.    Chromium*use  1n CCT's appears to be distributed  randomly
 across  the country.
       In the preparation of  the proposed  rule for CCT's under  the  Toxic
 Substances Control Act  (TSCA)  (see 52 FR  10206), EPA developed model  tower
 parameters and estimates of chromium emissions per model  tower to
 represent the population of CCT's  1n the  U.S.  Table 10 presents the model
 parameters and baseline  (i.e.,  low efficiency drift eliminator [LEDE])
 emission estimates/
      The emission estimates  in Table 10 are based on an emission factor
 developed from EPA- and  Industry-sponsored cooling tower emission tests.
 Because the emission factors developed to estimate Cr+s emissions from
 cooling towers are Independent of tower operating parameters (recirculation
 rate, chromate concentration, cooling range), the factors  are applicable
 to both CCT's and IPCT's.  Section 3.2.3.1 of this document discusses
 specific emission factors to use for estimating Cr+6 emissions from
cooling towers on a case-by-case basis.   [Note:   The proposed TSCA rule

                                     27

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                       TABLE 10.  MODEL COMFORT COOLING TOWERS AMD HOURLY BASELINE Cr*6 EMISSIONS
ro
oo
Model
tower
1
2
3
4
5
6
Model
building
•^(ft8)
673
(7,240)
1,460
(15,720)
3,405
(36.650)
6,224
(66,990)
12,338
(132,800)
37.626
(405,000)
Flow rates, ft /rain (gal/mln)
Model tower
cooling requirements
W (Btu/h)
95,400
(325,800)
207,100
(707,400)
482,900
(1,649,000)
882,900
(3,015,000)
1,750,000
(5,976,000)
5,338,000
(18,230,000)
Tons
27
59
137
251
498
1.520
Reclrcu-
1 at Ion
rate
246
(65)
534
(141)
1,250
(330)
2.280
.(602)
4,520
(1*194)
13.800
(3.642)
Evapora-
tion rate
2.08
(0.55)
4.54
(1.20)
10.6
(2.80)
19.4
(5.12)
38.4
(10.15)
117.0
(30.96)
Chromium
emissions
Slowdown per tower,
rate mg/h (lb/1,000 h)
0.53
(0.14)
1.14
(0.30)
2.65
(0.70)
4.85
(1.28)
9.61
(2.54)
29.3
(7.74)
19.9
(0.044)
43.2
(0.095)
101
(0.222)
184
(0.406)
365
(0.804)
1,110
(2.45)
        Assumptions:
        Wet bulb temperature = 23.9°C (75°F)
        Hot water temperature = 29.4°C (85"F)
        Cooling range = 5.6°C (10°F)  2
        Cooling requirements = 142 W/m  floorspace (45 Btu/ft /h)
        Cycles of concentration - 5
        Latent heat/total heat = 0.8
        Chromate concentration = 10 ppm
        Chromium emission factor = 0.0003 mg Cr*1" /(ppm Cr* Xlltet H20)   .
                                               (2.504x10   Ib Cr* /ppm Cr+
/gal H20)

-------
 would prohibit the use of chromium-based chemicals in CCT's.   If
 promulgated,  this rule would  have  the effect of reducing Cr+s  emissions
 from CCT's to zero.]
       3.2.1.3  Cooling Tower  Fundamentals.   Schematics of typical  cooling
                                     u a
 tower designs are shown in Figure  2.     The  major cooling tower components
 include the fan(s),  fill  material, water distribution deck or  header,
 drift eliminator, structural  frame,  and  cold water basin.   Other
 components that affect tower  operation include  the pumps and pipes
 necessary to  circulate the cooling water through  the  cooling tower and
 heat exchanger loops.
       Most IPCT's are  designed with  induced-draft airflow,  but many have
 forced-draft  airflow,  and  some (especially 1n the utilities industry)  have
 natural-draft airflow.   Induced draft  is provided by  a propeller-type
 axial  fan located in the  stack at the top of the  tower.   Forced-draft
 towers are usually smaller than induced-draft towers  and have  either
 centrifugal fans  located at the base of  the  tower,  which 1s constructed  as
 a plenum to provide positive-pressure airflow through  the fill  material,
 or axial  fans located  on the  side of the  tower.   Natural-draft  airflow
 relies on air currents  created by temperature differences between  the  air
 1n the tower  and  the atmosphere.  When the cooling  demands are  minimal and
 the  air temperature is  low enough, water  can  be circulated through  the
 tower  and cooled  sufficiently without using  the fans.   In these  Instances,
 a natural  draft Is created in the cooling tower.
       The direction of  the airflow through a mechanical  draft tower  is
 either crossflow or counterflow.  Crossflo./ refers to horizontal airflow
 through  the fill,  and counterflow refers to upward vertical airflow.   Fill
 material  is used to maintain an even distribution of water across the
 horizontal plane of the tower and to create as much water surface as
 practical  to  enhance evaporation and sensible heat transfer.
 3.2.2   Potential Emission Reduction Techniques
      Techniques to control chromium emissions from cooling towers  involve
 two different strategies:  modification of chromium addition to the
 reclrculatlng water, and improved reduction of drift.   The first technique
 involves reducing the concentration of chromium in the water treatment
program, thereby reducing the  concentration of chromium in the  drift
                                    29

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               WATER
               INLET
FAN
 WATER
 INLET
                        "*«  DRIFT
                        ^.ELIMINATORS
              WATER OUTLET
                    MECHANICAL  DRAFT
                    CROSS-FLOW  TOWER
                           AIR
                          OUTLET
                                 DRIFT
                            ELIMINATORS
          WATER  OUTLET
                 MECHANICAL  DRAFT
                 COUNTER-FLOW  TOWER
Figure 2.  Internals of crossflow and counterflow cooling towers
              (reprinted from Reference No.  48).
                              30

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 emitted.   The  second technique Involves retrofitting towers that normally
 have LEDE's  with  high-efficiency drift eliminators (HEDE's) to reduce
 drift emissions to the lowest possible rate.
       3.2.2.1  Alternative Water Treatment Programs.  Responses to 28 EPA
 Information  requests and  a survey of the Chemical  Manufacturers Associa-
 tion Indicate  that the average chromate concentration for those IPCT's
 using chromium-based corrosion inhibitors 1s  13  ppm.1*5'*9  One potential
 chromium emission reduction technique involves alternative water treatment
 programs such  as  programs with lower chromate levels or nonchromate
 treatments.
       A low-chromate treatment program would  reduce  Cr"1"6 emissions from
 IPCT's by  limiting the chromate concentration 1n cooling water.  Water
 treatment  programs are available that maintain average chromate concentra-
 tions  of 0*5 to 4 ppm 1n  the  recirculatlng water,  but these programs  have
 not  always been successful  in industrial  applications.   Low-chromate
 programs that  have provided acceptable results in  a  number of cases
 maintain chromate concentrations 1n  the range of 4 to 6 ppm.
       Because of  National  Pollution  Discharge Elimination System (NPDES)
 chromium restrictions  and  other regulations,  nonchromlum treatments are
 now  more widely used  than  chromium treatments.   The  most common
 nonchromium treatment  program 1s phosphate based,  but others  include
 molybdates, zinc,   and  all-organic treatments  (primarily organo-phosphorus
 compounds).  However,  these alternative programs may not perform corrosion
 Inhibition functions as well  or  as cheaply as chromates depending on  the
 Individual  cooling tower system.  The performance  of  any treatment  program
 is dependent on water quality parameters  (pH, alkalinity,  hardness, and
 conductivity) and  operating conditions  (water temperature,  flow velocity,
 Inhibitor concentration, and the presence of contaminants  such  as H2S,
 S02, NH3,  and N02) that are specific to each cooling  system.
      3.2.2.2  Low- and High-Efficiency Drift Eliminators.  Water droplets
 entrained  in the air and the dissolved and suspended  sol Ids contained in
 the droplets that  are emitted from cooling towers are referred  to as
drift.  Drift eliminators can be Installed at the exit of the fill
sections  to reduce the amount of drift 1n the exiting airflow.
Historically, the  purpose of drift reduction has  been to alleviate the
                                    31

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 nuisance  deposition of water drift  and  Its  dissolved  sol Ids  on nearby
 buildings or on  personal property such  as automobiles.   More recently,  the
 concern has  focused on the environmental Impact  caused  by  the compounds
 contained 1n the drift and, thus, on  the deposition of  these compounds.
 Drift eliminators are designed with pressure drops lower than those  of
 other air pollution control equipment and rely primarily upon the
 1mpact1on of water droplets on drift  eliminator  surfaces to  reduce the
 concentration of drift from the exit  air of cooling towers.   The drift
 eliminator blades are configured to force directional changes 1n the
 airflow such that the momentum of the water droplets  causes  them to
 Impinge onto the blade surfaces.  The number of  directional  airflow
 changes,  the spacing between the blade  surfaces, the  angle of directional
 change, and  the  capability to return  the collected water to  a quiescent
 area of the  plenum are the major design features (parameters)  1n drift
 eliminators  that affect efficiency.   Drift  eliminators  are constructed  of
 wood, PVC, metal, asbestos-cement,  polystyrene, or cellulose.   The
 material  most often specified 1s PVC.
      Figure 3 presents schematics  of the three major drift  eliminator
 designs:   herringbone (blade-type), waveform, and cellular (or  honey-
 comb).  Low-efficiency drift eliminators Include herringbone,  some
 waveform  (sinusoidal), and some cellular designs.  Herringbone  designs  are
 constructed  to create two or three major directional  changes  1n the
 airflow.  The blades are sloped 1n opposing directions  1n a manner that
 provides  drainage of the accumulated drift  Into the fill area.  The  blades
 typically are constructed of wood, but other materials  (e.g., metal  and
 asbestos  cement  board) also are used.  Waveform drift eliminators are
 configured 1n a  sinusoidal  wave pattern such that two major directional
 changes 1n the airflow are created.   The sinusoidal blades are constructed
 of asbestos  cement board or PVC material.  Cellular drift eliminators are
 configured with thinner blades  1n a honeycomb pattern.  The airflow
 passages  1n  the cellular drift  eliminators,  which are narrower than
passages  1n other designs,  reduce the distance a droplet must travel
 across the stream to Impact on  the surface.   Drainage of the collected
water to prevent reentralnment  1s not a design criteria of LEDE's.
                                    32

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                                        .wood Lath
                                        Staaos
                           HERRINGBONE
                           (BLADE-TYPE)
                           ELIMINATOR
                          WAVEFORM
                          ELIMINATOR
                          CELLULAR
                          ELIMINATOR
Figure 3.   Designs  of various drift eliminators (reprinted
                 from Reference No. 50).
                             33

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      High-efficiency drift  eliminators  include  a  few  of  both  cellular and
 sinusoidal designs.  The cellular HEDE's that  achieve  the higher
 efficiencies are designed with complex configurations  that contain
 numerous, closely constructed airflow passages.  Thin  materials of
 construction are used to reduce the area of blockage to the airflow  and
 minimize the pressure drop that is created by  the  eliminator.  For
 sinusoidal drift eliminators, the blades are placed closer together  in
 high-efficiency designs than in low-efficiency designs, and the exit is
 configured with a tip for draining captured water  that would otherwise be
 partially reentralned in the airflow.  Typically,  drainage of water  into a
 quiescent area of the tower  1s a major design  consideration of HEDE's.  A
 few drift eliminators installed 1n towers built  in recent  years are  more
 likely to be higher efficiency waveform or cellular units,  but the vast
 majority of older towers still have lower efficiency herringbone and
 waveform eliminators.
      The performance of a drift eliminator is affected primarily by the
 droplet or particle size and the airflow velocities through the drift
 eliminator.  Small droplets are created both from evaporation of larger
 droplets and the physical breakage of larger droplets Into  small
 droplets.  Parameters that affect the rate of evaporation and the size of
 droplets created include the water distribution system, the type of fill,
 the type of tower, the meteorological  conditions, and the temperature of
 the redrculatlng water.
      A drift eliminator manufacturer indicates that HEDE's can remove
80 to 90 percent or more of the drift discharged from low-efficiency
 herringbone drift eliminators.   *     These drift eliminator efficiencies,
 however, are based on data collected  with a test method that has  not been
 submitted to EPA for approval.
3.2.3  Cooling. Tower Emissions
      Three series of emission  tests  were conducted by  EPA on IPCT's
equipped with low- and  high-efficiency  drift  eliminators.   The  results of
these tests are presented 1n  the  next  section.
                                    34

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       3.2.3.1   Drift  and  Chromium Emissions.   The drift rate (rate of
 water  lost  by  entrainment in the cooling air  drawn through the tower) is
 often  expressed as  the  percentage of the recirculating water flow rate
 that is emitted.  Likewise,  the chromium emission rate can be expressed as
 a  percentage of the recirculating chromium rate.   However, the chromium
 emission rate  from  towers should not be  confused  with  the drift rate.
 Based  on test  results,  a  drift  eliminator manufacturer claims that the
 achievable  drift rates  range from 0.001  to 0.06 percent of the
 recirculating  water.  The approximate dividing  line between drift rates
 for higher  and lower  efficiency drift eliminators is 0.008 percent.   Those
 achieving a lower percentage are "higher efficiency,"  and those that
 cannot achieve 0.008  percent are "lower  efficiency."
       Drift can be  estimated by measuring the emission rate of an element
 (such  as sodium, calcium,  manganese,  chromium,  lithium or bromine)  and
 assuming that  the percentage of water emitted as  drift is the same as the
 percentage  of  the recirculating element  emitted.   However,  a claimed  drift
 rate may or may not be  equivalent to  the  element's  emission rate  depending
 on the way  the  drift  rate  was measured.   Also,  drift rate measurement
 results are highly dependent on the measurement method;  therefore,
 achievable  drift rate claims may not  be  comparable  1f  they are based  on
 different measurement methods.
      The EPA-sponsored emission tests of  IPCT's  at three facilities  used
 an isokinetic test method  for chromium which  is still  under development.
 Emission factors relating  the chromium emission rate to  the chromium
 recirculation rate were developed  from each of  these emission  tests.   The
 average baseline (LEDE) and  controlled (HEDE) emission factors  for each
 test site are presented in Table 11.  In  addition, five  industry-sponsored
 drift performance tests conducted  by Midwest  Research  Institute and two
 chromium emission tests conducted  by Mobil are  included.  The emission
 factors express the emission rate  as a percentage of the  recirculating
 rate (milligrams of chromium emitted per milligram of chromium
recirculating in the tower multipled by 100).   The most comprehensive
emission tests  were conducted at Plant B.  At this plant, two towers of
similar design  located side-by-side were tested simultaneously under the
same meteorological  conditions.   One tower was equipped with an LEDE and
the other was  equipped with an HEDE.

                                    35

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          TABLE  11.   EMISSION  FACTORS FOR HEXAVALENT CHROMIUM FROM
                           COOLING TOWERS33'5
Test  site
Chromium emission
factor, percent3
Standard deviation
(percent relative
standard deviation,
percent)
EPA-sponsored tests
A (HEDE)
C (HEDE)
B (HEDE)
B (LEDE)
A (LEDE)
Industry-sponsored tests
MRI No., 3 (HEDE)
MRI No. 4 (HEDE)
MobH-PTR Tower No. 5
(LEDE)
Mobil -North Tower No. 6
(LEDE)
MRI No. 1 (LEDE)
MRI No. 2 (LEDE)
MRI No. 5/6 minerals
test (LEDE)
0.0037
0.028 w/outl1ers
0.0038
0.0087
0.0267
0.0318
0.141 w/outT1ers

0.01
0.007
0.0334
0.0321
0.0305
0.034
0.018
0.021 w/out11ers
0.0020 (54)
0.035 w/outl1ers
0.0044 (116)
0.0037 (43)
0.0168 (63)
0.0292 (92)
0.192 w/outHers

NA (--)
NA (»)
0.0306 (92) .
0.0156 (49)
NA <--)
NA (--)
0.0045 (25)
0.0094 w/outllers
(126)



(136)







(45)
^Percentage of redrculatlng  chromium that  1s emitted.
                                    36

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       Since the completion of the emission tests at Plant B, additional
 methods development investigations have been conducted.   These
 investigations have revealed  that the chromium sampling  method is subject
 to substantial error due  to potentially severe problems  associated with
 chromium recovery and cross-over  contamination from sample run to sample
 run.   The extent to which these problems appear in the test results
 obtained at Plants A, C,  and  Mobil  1s uncertain.   As a result, the data
 presented in Table 11 should  be used  with caution.
       The EPA believes that the tests at Plant B  provide the best
 available data on the relative performance of  HEDE's.  The EPA Method 13-
 type  testing at Plant B Indicated a Cr+6 emission factor of 0.03  percent
 of the redrculatlng Cr+fi for LEDE's  and 0.0087 percent  for HEDE's.  As
 discussed in Section 3.2.1.2, these factors  can be  used  for both  IPCT's
 and CCT's.
       The current factors  are based on  the  assumption  that  the ratio  of
 hexavalent to total  chromium  1n the emissions  1s  the same  as  that in  the
 cooling water.   The test  program  conducted  by  the Agency has  not
 conclusively Identified the speciatlon  of  emissions  (i.e.,  Cr+ versus   .
 Cr+3).   For purposes  of estimating  Cr+   emissions,  the conservative
 assumption is that  all of the chromium  is Cr+  .
       3.2.3.2  Sample  Calculation of  Chromium  Emissions.  The  chromium
 emission  rate for any  tower can be  estimated by multiplying the emission
 factor  by the recirculating rate of water and  the chromium concentration
 1n  the  recirculating water as shown 1n  Equation (1).
                              ECr = K'R'cCr                            (D
where:
      E^r - chromium emission rate, mg Cr/min
        K » chromium emission factor,  percent of recirculating chromium
            that  is emitted
        R = recirculating  ra;e of  cooling water, liters/rain
      C,£r = concentration  of chromium  in the recirculating water,  mg
            Cr/liter = ppm (multiply CrO^ concentration by 0.448 to obtain
            Cr concentration)
For example, the following calculation estimates the emissions from a
10,000-gallon-per-minute (gal/min) IPCT with a recirculating chromate
                                    37

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concentration of  10 parts per million  (ppm),  equipped  with  a  low-
efficiency drift  eliminator.
        R -  (10,000 gal/m1n)(3.785  liters/gallon) *  37,850  Uters/mlnute
      C^r »  10 ppm as CrOu 3 4.48 ppm  Cr
        K *  the emission factor for towers with  low-efficiency drift
             eliminators; use K = 0.03  percent.
      ECr -  K'R«CCr - (0.03J£)(37t850)(4.48) - (0.0003)(37,850)(4.48)  -
             50.9  mg Cr em1tted/m1n
To estimate  the emissions from the same IPCT  equipped  with  a  high-
efficiency drift  eliminator, use K » 0.0087.
Therefore:

ECr - K«R«CCr * (0.0087SS)(37,850)(4.48) » (0,000087)(37,850)(4.48) =
                          14.8 mg Cr em1tted/m1n
Thus, the emission reduction achieved  by a HEDE  compared to a LEDE 1s:
                                        71  percent.
      The following example calculation estimates the emissions from a
500-gal/m1n CCT with a reclrculatlng chromate concentration of 10 ppm,
equipped with a low-efficiency drift eliminator.
        R - (500 ga1/m1n)(3.785 Uters/gal) - 1,892.5 11ters/m1n
      C£r « 10 ppm as CrO,, » 4.48 ppm Cr
        K » 0.03 percent
      ECr » K»R«CCr - (0.03*)(1,892.5)(4.48) -
            (0.0003)(1,892.5)(4.48) - 2.5 mg Cr emitted/rain

3.2.4  Nationwide Emissions Distribution by Industry
      In developing the NESHAP for chromium emissions from IPCT's, EPA has
generated Industry-by-lndustry estimates of the total number of cooling
towers, the number of towers using chromate treatments, and chromium
emissions.  Table 12 presents these estimates as currently known.   The
data show that the Industries of greatest concern are chemical  manufac-
turing (43 Mg/yr [47,5 tons/yr]),  petroleum refining (31.8 Mg/yr
[35.1 tons/yr]), and primary metals production (8.4 Mg/yr [9.3  tons/yr]).
                                    38

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Together, these industries represent 98.2 percent of nationwide chromium
emissions from IPCT's.    Tabli
chromium emissions from CCT's.
emissions from IPCT's.    Table 12 also presents nationwide estimates of
                                   39

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   TABLE  12.  NATIONWIDE COOLING TOWER CHROMIUM  EMISSIONS  SUMMARY
Industry
Chemical manufacturing
Petroleum refining
Primary metals
Tobacco products
T1re and rubber
Textile finishing
Glass manufacturing
Utilities
Subtotal (IPCT only)
Comfort cooling towers
TOTAL
Total No.
of cooling
towers
5,096
680
1,118
336
267
1,018
58
775
9,348
250,000
259,350
No. of
cooling towers
using cnromate
2,039
476
224
16
40
51
3
6
2,855
37,500
40,360
Cr*6
Mg/yr
43.13
31.82
8.39
0.23
0.18
0.08
0.01
0.95
84.8
33
118
em1ssionsa
Tons/yr
47.54
35.08
9.25
0.26
0.20
0.09
0.01
1.05
93.5
34
128
aBased on use of low-efficiency drift eliminators.
                                    40

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                         4.0   SOURCE  TEST PROCEDURES

 4.1  CHROMIUM ELECTROPLATING
       During the standards support study for hexavalent chromium emissions
 from hard and decorative chromium electroplating facilities,  samples to be
 analyzed for hexavalent and  total chromium were obtained in accordance
 with EPA Method 5 (40 CFR Part 60-Appendix A),  also  referred  to as
 Modified Method 13-B in test reports.   The only modification  to the sample
 collection method was the elimination  of the filter  and the replacement of
 H20 in the impingers with 0.1 Normal sodium hydroxide.   Method  5 provides
 detailed procedures  and equipment criteria and  other considerations
 necessary to obtain  accurate and  representative emission samples.   In
 order to sample for  chromium emissions,  Methoas 1  through  4 must also be
 used.
       After collection, the  samples  were analyzed  for hexavalent and total
 chromium (total chromium is  the sum  of hexavalent  chromium plus other
 chromium).   Concentrations of hexavalent chromium  were  determined  using
 spectrophotometric analysis  while total  chromium was  determined using
 inductively coupled  argon plasmography (ICAP).  At the  present  time,
 sample analysis has  been performed in  accordance with the  tentative method
 "Detection  of Hexavalent Chromium from Stationary  Sources  (December 13,
 1984),"  and a draft  method:   "E.P.A. Protocol for  Emission  Sampling for
 Both  Hexavalent and  Total Chromium (February 22, 1985)."
 4.2   COOLING  TOWERS
       During  the  standards support study for chromium emissions  from
 cooling  towers, testing  was  conducted  according to two draft test methods
 developed from previously conducted methods development testing:
 "Method  	—Determination of Chromium Emissions from Cooling Towers" and
 "Method  	—Direct Measurement  of Gas  Velocity and Volumetric  Flowrate
 Under  Cyclonic  Flow Conditions (Propeller Anemometer)."   The cooling  tower
method is similar to EPA Method 13 (40  CFR Part 60-Appendix A) with the
following exceptions:   (1) a Teflon"1 filter is used in place of a paper
filter,  (2) a propeller anemometer is used in place of the pitot tube for
gas velocity and flowrate measurements,  (3) the determination of the
measurement site does not follow EPA Method 1, and (4) the chemical
                                    41

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 analysis  for  total  chromium  1n  the  emission  samples  1s  performed  using
 Neutron Activation  Analysis  (NAA),  Graphite  Furnace  Atomic Absorption
 (GFAA), or  ICAP.  In  conjunction with the emissions  testing,  repre-
 sentative cooling tower water samples were collected to determine the
 ratio of  hexavalent to total chromium 1n the cooling water; these samples
 were analyzed for total chromium by NAA, GFAA,  or  ICAP  and for  hexavalent
 chromium  by the dlphenylcarbazlde colorlmetrlc  method (1n  "EPA  Draft
 Method-Determination  of Hexavalent Chromium  Emissions from Stationary
 Sources," December  13, 1984).   The ratio was used  to calculate  the  amount
 of hexavalent chromium 1n the cooling tower emissions.
      Preliminary material balance calculations were performed  on the
 cooling water at several towers to compare the  apparent chromium  loss In
 the drift emissions with the emission measurements obtained during  the
 standards support study.  Variables used 1n these calculations  Included:
 cooling water flow  rates to the towers, riser cells,  and/or fan cells;
 blowdown rates; makeup water flow rates; addition(s)  of chemicals to  the
 cooling water; and  chemical analysis of the cooling  water  samples taken
 during testing.
      Two major modifications were made to the  draft  test method  for
 cooling towers based on problems encountered and knowledge gained during
 the testing program.  Initially, the draft method specified the use of NAA
 to determine  the total chromium content of the  1mp1nger  train samples and
 the cooling water samples.  Because of the length of  time required for
 sample analysis and the limited availability of commercial  NAA services,
 two additional analytical  techniques,  GFAA and  ICAP, were utilized and
were added as options to the draft test method.  Unlike  NAA, both of these
techniques require acid solubilization of the chromium  1n the sample prior
to analysis.  In assessing the chromium recovery efficiency for the
concentrated 1mp1nger samples from the first test,  it was discovered that
a significant residue remained in the  beakers used  to concentrate the
samples.   The concentration  procedure  was modified  to require  an acid
rinse of  the beakers used  for sample concentration  with  the rinse being
added to  the concentrated  sample.
                                    42

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                              5.0  REFERENCES
  1.  Memo from Hester, C., MRI,  to Smith, A., EPA/ISB.   Bases for Risk
     Assessment  Inputs for Chromium Electroplating Operations.  June
     1988.  pp.  6-7,  10.
  2.  Memo from Hester, C., MRI,  to Smith, A., EPA/ISB.   Bases for Risk
     Assessment  Inputs for Chromic Add Anodizing Operations.  June
     1988.  pp.  8-9.
  3.  Logozzo, A., and Schuwartz, M.  Hard Chromium Plating.  American
     Electroplaters Society,  Inc.  p. 9.
  4.  Vervaert, A.  Preliminary Assessment of Chromium from Chromium
     Electroplating Facilities.  Research Triangle Park, North Carolina.
     U. S. Environmental Protection Agency,  p. 3.
  5.  Decorative  Chromium Electroplating.  American Electroplaters
     Society.  1980.  p. 2.
  6.  Dennis, J., and Such, T.  Nickel and Chromium Plating, Butterworth
     and Company.  University Press.  Cambridge, England, Second
     Edition.  1986.  p. 179.
  7.  Reference 4, p. 2.
                                                                   *
  8.  Reference 6, p. 287.
 9.  Reference 6, p. 289.
10.  Reference 6, p. 290.
11.  Reference 6, pp. 272, 294-295.
12.  Locating and Estimating Air Emissions From Sources of Chromium.
     U. S. Environmental Protection Agency, Research Triangle Park,  North
     Carolina.  EPA Publication No. 450/4-84-007g.  July 1984.  p.  83.
13.  Graham, K.   Electroplating Engineering Handbook.  Reinhold  Book
     Corp.,  New York.  1962.   p.  427.
14.  Reference 13,  p. 432.
15.  Reference 13,  p. 432.
16.  Reference 13,  pp. 162» 427.
17.  Brace,  A.  The Technology of Anodizing Aluminum.  Robert Draper,
     Ltd.  Teddington, 1968.   p.  54.
18.  Darrln,  M.,  and Tubbs,  L.  "Dyeing  Chromic  Acid  Anodized Aluminum."
     Metal Finishing.   September  1984.   p.  550.
                                    43

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19.  Schwartz, M.  Anodlzed Aluminum and Its Alloys.  American
     Electroplaters Society.   1985.  p. 15.

20.  Wernlck, S., and Pinner,  R.  "Surface Treatment and Finishing of
     Light Metals."  Metal Finishing.  June 1955.  p. 92.

21.  Reference 13, p. 429.

22.  Reference 13, p. 429.

23.  Br1m1, M.f and Luck, J.   Electroflnlshlng.  American Elsevler
     Publishing Company.  New  York.  1981,  p. 77.

24.  Reference 13, p. 430.

25.  Snyder, D.  "THvalent Chrom'lum Plating:  The Second Decade."
     Product Finishing.  March 1988.  p. 57.

26,  Reference 25, pp. 59-60.

27.  Reference 25, p. 63.

28.  Reference 25.  p. 65.

29.  TMvalent Chromium Cost Enclosure:  Harshaw/FHtrol Partnership.
     Prepared for IK S. Environmental Protection Agency, Research Triangle
     Park, North Carolina, by Dennis Maserlk, Manager of Technical
     Services.  June 22, 1987.  p. 3.

30.  Tomaszewskl, T., and Fischer, R.  "Trlvalent Chromium:  A
     Commercially Viable Alternative."  Occidental Chemical Crop.  p. 5.

31.  Reference 30, p. 5-6.

32.  Chromium Electroplaters Test Report:   Greensboro Industrial Platers,
     Greensboro, North Carolina.   Entropy  Environmentalists, Inc.,
     Research Triangle Park, North Carolina.  Prepared for U. S.
     Environmental Protection Agency, Research Triangle Park, North
     Carolina.  EM8 Report 86-CEP-l.  March 1986.

33.  Chromium Electroplaters Test Report:   Consolidated Engravers
     Corporation, Charlotte, North Carolina.  Peer Consultants,  Inc.,
     Rockvllle, Maryland,  Prepared for U.  S.  Environmental  Protection
     Agency, Research Triangle Park, North  Carolina.   EMB
     Report S7-CEP-9.  May 1987.

34.  Chromium Electroplaters Test Report:   Roll  Technology,  Greenville,
     South Carolina.  Peer Consultants, Inc.,  Dayton,  Ohio.   Prepared for
     U. S. Environmental  Protection Agency, Research  Triangle Park, North
     Carolina.  EMB Report 87-CEP-6.  September  1987.
                                    44

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 35.   Chromium Electroplaters  Test  Report:   Able  Machine  Company,  Taylors,
      South  Carolina.   PEI  Associates,  Inc., Cincinnati,  Ohio.   Prepared
      for U.  S.  Environmental  Protection Agency,  Research Triangle Park,
      North  Carolina.   EMB  Report 86-CEP-3.   June 1986,

 36.   Chromium Electroplaters  Test  Report:   Roll  Technology  Corporation,
      Greenville, South Carolina.   Peer Consultants,  Dayton,  Ohio.
      Prepared for U.  S.  Environmental  Protection Agency, Research Triangle
      Park,  North Carolina.  EMB Report 88-CEP-13.  August 1988.

 37.   Chromium Electroplaters  Test  Report:   Precision Machine and
      Hydraulic, Inc.,  Worthington, West Virginia.  Peer  Consultants,
      Dayton,  Ohio.  Prepared  for U. S.  Environmental Protection Agency,
      Research Triangle Park,  North Carolina.   EMB Report 88-CEP-14.
      September 1988.

 38.   Chromium Electroplaters  Test  Report:   Hard  Chrome Specialists, York,
      Pennsylvania.  Peer Consultants,  Dayton,  Ohio.  Prepared for U. S.
      Environmental Protection Agency,  Research Triangle  Park, North
      Carolina.  EMB Report-89-CEP-15.   January 1989.

 39.   Emission Test Report:  Norfolk Naval Shipyard, Norfolk, Virginia.
      Naval Energy and  Environmental Support Activity, Port Hueneme,
      California.  Source Emission Testing of the Building 195 Plating Shop
      at  Norfolk Naval  Shipyard, Portsmouth, Virginia.  March 11-18,
      1985.  NEESA 2-124.  May 1985.

 40.   Chromium Electroplaters Test Report:   Piedmont Industrial Platers,
      Statesville, North Carolina.  Entropy  Environmentalists, Inc.,
      Research Triangle Park, North Carolina.   Prepared for U. S.
      Environmental  Protection Agency, Research Triangle Park, North
      Carolina.  EMB Report 86-CEP-04.  September 1986.

 41,   Chromium Electroplaters Test Report:  Steel  Heddle,  Inc., Greenville,
      South Carolina.   PEI Associates, Inc., Cincinnati, Ohio.  Prepared
      for U. S. Environmental Protection Agency, Research  Triangle Park,
      North Carolina.   EMB Report 86-CEP-2.  June 1986.

42.   Chromium Electroplaters Test Report:  GMC Delco Products Division,
      Livonia, Michigan.  Peer Consultants, Inc.  Rockville,  Maryland.
      Prepared for U.  S. Environmental  Protection  Agency,  Research Triangle
      Park, North Carolina.   EMB Report 87-CEP-7.   May 1987.

43.  Draft Chromium Electroplaters  Test Report:  A Plant  in  the  Midwest.
     Prepared for U.  S. Environmental  Protection  Agency,  Research Triangle
     Park, North Carolina.   April  1988.

44.  Memo from Barker, R.,  MRI,  to  Vervaert, A.,  EPA/ISB. Engineering
     Analysis - Reliable Plating and  Polishing Company.   May 1987.
     pp.  5-7.
                                    45

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45.  Chromium Emissions from Industrial Process Cooling Towers-Background
     Information for Proposed Standards.  Draft.  Prepared for LI. S.
     Environmental Protection Agency.  Research Triangle Park, North
     Carolina.  May 1988.

46,  Telecon.  P. BelUn, MRI, with C. Bergesen, Utility Data Institute
     (UDI),  March 5, 1986.  UDI study on chromate use 1n electric
     utilities Industry.

47.  Chromium Emissions from Comfort Cooling Towers-Background Information
     for Proposed Standards.  Prepared for U. S. Environmental Protection
     Agency.  Research Triangle Park, North Carolina.  March 1988.
     EPA-450/3-87-010a.

48.  Holmberg, J. 0., and 0. L. Klnney.  Drift Technology for Cooling
     Towers.  The Marley Company, Mission, Kansas.  1973.

49.  Letter and attachments.  Mayer, A., Chemical Manufacturers
     Association, to Cuffe, S., EPA:ISB.  September 27, 1986.  Summary of
     CMA member survey on corrosion Inhibitors used 1n process cooling
     towers Including average ppm in redrculatlng water.

50.  Telecon:  C. Clark, MRI, with J. Holmberg, Marley Cooling Tower
     Company.  April 2, 1985.  Drift eliminator efficiency.

51.  Telecon:  P. BelUn, MRI, with J. Holmberg, Marley'Cooling Tower
     Company.  July 19, 1985.  Drift eliminator efficiency.

52,  Kelly, G. M.  A System Efficient-Approach to Cooling Tower Energy
     Modifications.  Cooling Tower Institute Technical Paper.
     No. TP-85-18.  New Orleans, Louisiana.   January 1985,

53.  Emission Test Report:  National Bureau  of Standards, Galthersburg,
     Maryland.  EMB Report 85-CCT-4.  October 1986.

54.  Emission Test Report:  Exxon Company Petroleum Refinery, Baytown,
     Texas.  EMB Report 85-CCT-3.  November  1986.

55.  Emission Test Report:  Southeastern Manufacturing Facility.   EMB
     Report 87-CCT-5.   Draft.  September 1987.

56.  Abstracts of six  confidential  emission  test reports  conducted by MRI
     for Industrial clients.

57.  Letter and attachments.  Hawes, R.,  Mobil  011  Corp.,  to  Randall, D.,
     MRI.   August 24,  1987,   Emission test results.
                                    46

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                                   TECHNICAL REPORT DATA

'• TSX7SS8-2-89-002 i2' X«C,«.NT,ACC«».ONNO.
4. TITLE AND SUBTITLE
Locating And Estimating Air Emissions From Sources
of Chromium (Supplement)
7. AUTHOfl(S)
Jeff Shular, Robin Barker, Bruce Nicholson,
David Randall
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Midwest Research Institute
401 Harrison Oaks Boulevard
Gary, North Carolina 27513
12. SPONSORING AGENCY NAME ANO ADDRESS
U. S. Environmental Protection Agency
OAR, OAQPS, AQMD, PCS (MD-15)
Research Triangle Park, North Carolina 27711
5. REPORT DATE
August 1989
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-4395
13. TYPE OF REPORT ANO PERIOD COVERED
Fi na 1
14. SPONSORING AGENCY CODE
i
15. SUPPLEMENTARY NOTES
EPA Project Officer: Dallas U. Safriet
 16. ABSTRACT
  To assist groups  inventorying air emissions of potentially toxic substances, EPA
  is preparing a  series  of  documents that compiles available information on sources
  and emissions of  toxic substances.  This  document deals specifically with methods to
  estimate chromium (Cr+6)  emissions from cooling towers and electroplating operations.
17. KEY WORDS ANO DOCUMENT ANALYSIS
a. DESCRIPTORS
Chromium (Cr+6)
Estimating Air Emissions
Air Toxic
Cooling Towers
Electroplating
18. DISTRIBUTION STATEMENT
Unlimited
b.lOENTIFIERS/OPEN ENDED TERMS

19. SECURITY CLASS (Tfiis Report!
Unclassified
20. SECURITY CLASS / This page)
Unclassified
c. COSATI Field/Group

21. NO. OF PAGES
50
22. PRICE
EPA F«* 2220-1
». 4— 77)   PACV1OU3 EDITION t* OBSOLETE

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