453F95001
United States
Environmental Protection
Agency
EPA-453/F-95-001
March 1995
Office of Air Quality Planning & Standards (MD-10)
m EPA
New Regulation
Controlling Air
Emissions from
Chromium
Electroplating and
Anodizing Tanks
Printed on recycled paper
-------
ERA'S NEW REGULATION CONTROLLING AIR EMISSIONS
In November 1994, the U. S. Environmental Protection
Agency (EPA) issued national regulations to control
air emissions of chromium from chromium
electroplating and anodizing tanks. The regulation
appeared in the January 25,1995 edition of the Federal
Register [volume 60, beginning on page 4948]. The
regulation affects ajl facilities performing hard and
decorative chromium electroplating and chromium
anodizing, regardless of size. Over 5,000 facilities are
affected nationwide.
Why is EPA regulating electroplating
and anodizing tanks?
TheCleanAirAct(CAA),asamended in 1990,directs
EPA to regulate emissions of 189 toxic chemicals,
including chromium compounds, from a wide range of
industrial sources. EPA is regulating emissions of
chromium from electroplating and anodizing tanksto
meet the requirements of the CAA. The hexavalent
form of chromium is highly toxic and strongly
suspected of causing lung cancer. Less is known
about the cancer risk of thetrivalent form of chromium,
but it can accumulate inthelungsand may decrease
lung function after continuous exposure.
Hard chromium electroplating operations deposit a
thick layer of chromium directly on a base metal to
provide wear and corrosion resistance, low friction,
and hardness (for hydraulic cylinders, industrial rolls,
etc.). Decorativechromium electroplating operations
deposit a thin layer of chromium on a base metal,
plastic, or undercoating to provide a bright finish and
wear and tarnish resistance (for bicycles, auto trim,
tools, etc.). Chromium anodizing operations form a
chromium oxide layer on aluminum to provide corrosion
and wear resistance (for aircraft parts, architectural
structures, etc.). Exceptforthetrichrome decorative
process, which uses thetrivalentform of chromium,all
other electroplating processes use the hexavalent
form of chromium.
Chromium electroplating and anodizing tanks are one
of the largest sources of chromium emissions. Over
5,000 facilities with chromium electroplating and/or
anodizing tanks exist in the United States; many are
located in small shops (using one plating tank) that are
within close proximity to residential areas. EPA
estimates that full compliance with its new
regulation will result in a reduction of about 173 tons of
chromium emitted into the air annually, or about a
99 percent reduction from today's levels.
*
••••^m How does the new EPA regulation
affect you?
The regulation affects all facilities that use chromium
electroplating oranodizing tanks, regardless of size.
How you are affected depends on the size and type of
shop (hard, decorative, or anodizing) you have and the
technique thatyou use to reduce emissions. Decorative
chromium electroplating operations must be in
compliance with the regulation by January 25,1996.
Hard chromium electroplating andchromium anodizing
operations must comply by January 25, 1997. In
general, the regulation requires:
^Emission limits ^Ongoing monitoring
•/ Work practice standards /" Recordkeeping
^Initial testing ^Reporting
These requirements are summarized below. Also,
EPA has published a guidebookentitled "A Guidebook
on HowtoComplywiththeChromium Electroplating
and Anodizing National Emission Standards for
Hazardous Air Pollutants" (EPA-453/B-95-001) that
provides a more detailed explanation of the regulation.
(See the back of this pamphlet for information on how
to obtain a copy.)
Emission Limits
The regulation specifies emission limits (expressed as
concentration of chromium in milligrams per dry
standard cubic meter [mg/dscm] of exhaust air) that can
typically be achieved by the use of a certain technique
to reduce emissions (such as a control device orfume
suppressant). The emission reduction technique that
corresponds to the emission limit is shown in the
following table. However, you may use another
technique, as long as the level of emission reduction is
the same or better.
Work Practice Standards
The regulation specifies work practice standards, which
include:
^ Preparation of an operation and maintenance plan.
^ Quarterly inspections of control devices, ductwork,
and monitoring equipment.
^ Periodic washdown of composite mesh-pad systems.
•/ Fresh water additions to the top of packed-bed
scrubbers.
-------
iM CHROMIUM ELECTROPLATING AND ANODIZING TANKS
Affected
tanks
Emission
limit
Emission
reduction technique
Hard Chromium Plating Tanks
Small,
existing
tanks'
All other
tanks6
0.03 mg/dscm
0.015 mg/dscm
Packed-bed scrubber
(PBS)
Composite mesh-pad
(CMP) system
Decorative Chromium Plating Tanks Using a Chromic
Acid Bath
Alltanks"
0.01 mg/dscm or
45 dynes/cm
Fume suppressant (FS)
FS that contains a
wetting agent
Decorative Chromium Plating Tanks Using a Trivalent
Chromium Bath
All tanks6
Only subject to recordkeeping and reporting
Chromium Anodizing Tanks
Alltanks6
0.01 mg/dscm or
45 dynes/cm
FS
FS that contains a
wetting agent
"Small means tanks having a maximum potential rectifier
capacity of less than 60 million ampere-hours per year.
Existing means installed before 12/16/93.
""Includes newtanks.
Initial Testing
A one-time test is required by July 23, 1996 for
decorative chromium platers and by July 24, 1997
for hard chromium platers 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: (1) 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), or
(2) decorative chromium plating tanks that use a
trivalent chromium bath. The regulation contains
test methods for measuring the chromium
concentration discharged to the atmosphere (EPA
Reference Methods 306 and 306A) and for measuring
the surface tension of the bath (EPA Reference
Method 306B).
EPA has produced a videotape on stack sampling
and monitoring entitled "Construction and
Operation of the EPA Method 306A Sampling Train
and Practical Suggestions for Monitoring of
Electroplating and Anodizing Facilities" that is
available to you for a nominal fee by calling North
Carolina State University at (919) 515-4659.
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
CMP
PBS
CMP/PBS
Fiber-bed mist
eliminator
(FBME)
Wetting agent
Foam blanket
What to monitor
Pressure drop across unit
Inlet velocity pressure &
pressure drop across unit
Pressure drop across unit
Pressure drop across
FBME & across upstream
unit
Surfacetensionofbath
Foam thickness
How often
Once per day
Once per day
Once per day
Once per day
Once every
4 hours'*
Once per
hour3
"The time between monitoring may be increased gradually
if the emission limit is not exceeded.
"Does not apply to trivalent chromium baths with wetting
agents.
Sample monitoring checklists are included in the
EPA guidebook on howto comply with this regulation.
Recordkeeping
The regulation requires that sources keep records to
document compliance with the regulation. Records
include inspection records, equipment maintenance
records, records of malfunctions and exceedances,
performance test results, and monitoring data. All
records must be kept for 5 years. If you operate a
decorative chromium plating tankthat uses a trivalent
chromium bath, you only need to keep records of bath
component purchases.
Sample recordkeeping forms are included in the
EPAguidebookonhowtocomply with this regulation.
-------
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 Tanks Using a Chromic
Add Bath
Compliance deadline
Testing deadline
Notification of performance test
Notification of compliance status
Notification of test results
1/25/96
7/23/96 •
>60 days before test
<90 days after test or
2/24/96 if no test is
required
<90 days after test
Decorative Chromium Plating Tanks Using a Trivalent
Chromium Bath
Notification of compliance status
Notification of process change
2/24/96
<30 days after change
Hard Chromium Plating and Chromium Anodizing Tanks
Compliance deadline
Testing deadline
Notification of performance test
Notification of compliance status
Notification of test results
1/25/97
7/24/97
>60 days before test
<90 days after test or
2/24/97 if no test is
required
<90 days after test
Note: > means "at least"; < means "no more than."
Inaddition, major sources (emitting 10 tons peryear or
more of chromium or 25 tons per year or more of a
combination of hazardous air pollutants) must submit
semiannual reports that contain information on the
compliance status of the source. Check with the EPA
Regional Office for your State or territory to see if
reports should be sent to the Regional Office or to the
delegated State authority. All other sources must
complete a compliance status report annually and
keep the report onsite.
Sample reporting forms are included in the EPA
guidebook on howto comply with this regulation.
^^^•^•^B What pollution prevention options
exist?
There are several pollution prevention options in this
regulation. Source reduction techniques include:
(1) the use offumesuppressantsto inhibit chromium
emissions at the source (i.e. the bath) and (2) the use
of atrivalent chromium bath insteadof a hexavalent
chromium (chromic acid) bath to lowertotal chromium
emissions and lower chromium concentrations in
process wastewaters (thus, less sludge generated). 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 wastewatertreatment burden of a facility.
^^•^•^••i How does the new EPA regulation
relate to State or local requirements?
State or local requirements that may have affected
you prior to the new Federal EPA regulation continue
to apply. The new EPA regulation is the minimum
emission reduction that is required nationally. Some
State and local agencies do require stricter limits.
In addition, the format of some State requirements
may differ from EPA's regulation. Testing will
always give you the chromium concentration in
mg/dscm; other formats, such as percent control or
mg/ampere-hour, may be derived from mg/dscm.
All major sources are required to obtain a Title V
operating permit. A sample model permit is included in
EPA's guidebookon howto comply with this regulation.
The EPA is considering amending the regulation to
allow States to defer all nonmajor sources from Title V
permitting requirements for five years (up to
November 1999). ContactyourStateorlocalairpollution
control agency oryourState Small Business Assistance
Program for more information on permitting.
•••••••• How much will it cost?
The cost of compliance will vary considerably from
facility to facility. The average price to purchase a
packed-bed scrubber (PBS) or a composite mesh-pad
(CMP) system ranges from $27,000 to $186,000
depending on the size of your operation. Ongoing
annual costs related to upkeep of these emission
reduction devices range from $10,000 to $45,000 for a
PBS and from $14,000 to $84,000 for a CMP system.
Ongoing annual fume suppressant costs range from
$1,000 to $17,000. The initial compliance test will cost
about $1,150 per stack if you perform the test inhouse or
$4,500 per stack if you use a contractor. The ongoing
annual costs for monitoring, recordkeeping, and
reporting are $2,300 per facility on average.
-------
Whom can you contact for additional
information?
For more information on this regulation, EPA's testing
videotape, or EPA's guidebook on how to comply with
this rule, please call your State or local air pollution
control agency. You can also call your local, regional,
or national metal finishers trade association;your State
Small Business Assistance Program; or your State
Small Business Ombudsman. Contact EPA's Control
Technology Center (CTC) Hotline at (919) 541-0800to
get information on your State small business program
contacts. Acopy of the regulation can be obtained from
the Federal Register (January 25,1995) orthe EPA's
Technology Transfer Network (TTN). TheTTNcanbe
accessed via modem by dialing (919) 541-5742. Call
(919) 541-5384 for TTN assistance.
The EPA is divided into 10 geographic regions. You
may also call the Regional Office where your State or
territory resides for more information.
Region
1
2
3
4
5
6
7
8
9
10
States
CT, ME, MA, NH, Rl, & VT
NJ, NY, Puerto Rico, &
Virgin Islands
DE, MD, PA, VA, WV,
& District of Columbia
AL, FL, GA, KY, MS, NC,
SC, & TN
IL, IN, MI,WI, MN, &OH
AR, LA, NM, OK, &TX
IA, KS, MO, & NE
CO, MT, ND, SD, UT, &
WY
AZ, CA, HI, NV,
American Samoa, & Guam
AK, ID, WA, & OR
Telephone No.
(617) 565-3728
(212) 264-6676
(215) 597-3237
(404) 347-2864
(312) 886-6793
(214) 665-7225
(913) 551-7097
(303) 293-1886
(415) 744-1143
(206) 553-1949
Theinformationinthispamphletisintendedforgeneralreferenceonly;itis
not a full and complete statement of the technical or legal requirements
associated with the regulation.
*U.S. GOVERNMENT PRINTING OFFICE 1995*629-820
------- |