International Technical Conference Proceedings
            June 22-25,1992

        Session N—Environmental ill

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 ATMOSPHERIC RELEASES OF HEXAVALENT CHROMIUM PROM HARD CHROMIUM
                       PLATING OPERATIONS
              By Mitchell S. Hall, John D. Dietz,
       C. David Cooper, Roger L. Wayson, and Doug Bauman
                 University of Central Florida
                 4000 Central  Florida Boulevard
                        P.O. Box 25000
                  Orlando, Florida 32816-0450

Introduction
The  University  of  Central  Florida  Department  of  Civil  and
Environmental Engineering is investigating methods for improved
estimation  of  chemical releases which  require reporting under
provisions of SARA Title III  (Toxic Release Inventory, Form R).

This paper describes results from a research project  initiated in
the Fall  of 1990.    The preliminary objective was  to help the
surface  finishing  industry  to  identify  and  solve  specific
problems with completion of Form R.  A problem would generally be
defined as a combination of a process (e.g., hard chrome plating)
and  a  release  (e.g.,  fugitive   air releases  of  hexavalent
chromium).  It was concluded that the majority of environmental
releases  (water and  sludges)  are  subject  to  some form  of
monitoring in conjunction with an operating permit.  Accordingly,
monitoring data  is usually  available to  suppqrt  completion of
Form R.  The principal exception to this generalization concerns
air emissions, particularly fugitive emissions.
                                            ••*
The  initial  process  selected for  field .characterization  was
hexavalent  chromium releases  from hard -fchrome  plating.   The
sampling effort involved simultaneous  quantification of fugitive
emissions and emissions through existing tank ventilation systems
into the stack.

Stack Results - Hexavalent Chromium
Discussion of Data  Sources
Chromium may exist in several valence states, each with its own
physical, chemical, and toxicological  properties.  While Cr(III)
is naturally occurring, is relatively non-toxic (and in fact is
an essential dietary mineral), Cr(VI)  is classified by the U.S.
EPA as a  known human  respiratory carcinogen .  One main source of
Cr(VI) is  the electroplating  industry  where ,Cr(VI)  mists  are
emitted from hard chrome plating baths.  Other plating processes
such as trivalent chromium plating and chromic.acid anodizing are
not believed to be  significant emitters of toxic pollutants.

Extensive  studies  have  been  done, primarily  by  the EPA , to
evaluate atmospheric releases of chromium  and  to  determine the
efficiency of control devices.  Facilities selected for emission
testing  were representative  of hard chromium  electroplating
operations based on the size of the plating tanks, the types of
parts plated, and the plating bath operating parameters.
                                                                    767

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       Data  from  eight  of  these  EPA  tests   (where  all  operating
       parameters  were   defined)   were  reviewed   and  analyzed  to
       characterize  stack emissions of  Cr(VI).   Two  facilities were
       visited by  the project team to supplement the  EPA data and to
       complete   field   measurement   characterization   of    fugitive
       hexavalent chromium emissions.  One plant was visited by  both the
       EPA and our project team.

       Stack sampling of  Cr(VT) was accomplished using an EPA Modified
       Method  13B  isokinetic  sampling  train.    Indoor   ambient air
       sampling  for  the  two  sites occurred  simultaneously  using the
       fugitive  sampling  device described in a  subsequent section of
       this manuscript.

       Modeling  Effort
       Electroplating  operations  require an  electrical   current for
       plating deposits.   Only about 10  to  20 percent  of the current
       applied is used to deposit chromium on the item plated.  Eighty
       to ninety percent is consumed by the evolution of  hydrogen gas at
       the cathode with the resulting liberation of gas bubbles.  When
       these  gas bubbles  rise to  the  surface,  they  burst,  causing
       releases  of- chromic acid mist into  the  air.  The  rate of gas
       formation  is   a  function of  the  chemical  or  electrochemical
       activity  in the  tank and increases with  the amount of plating
       work in the tank, the strength and temperature of the solution,
       and the current densities in the plating bath. "

       The variability in hexavalent chromium stack emissions documented
       in  the  literature may  be  attributed  to  the multi-dimensional
       nature of the  process.  A large number of variables influence the
       amount of Cr(VI)  released prior to reaching a  control  device.
       Items of information were extracted,  if available, for each test
       run from  the database  for the  purpose of  modeling  uncontrolled
       stack emissions.  These items were:

          * Test Site Identification
          * Reference Document (if from EPA study)
          * Process Information  (Type of  process, Tank dimensions and
                 volume,   Freeboard,    Hexavalent   chromium   tank
                 concentration, Bath temperature, Agitation, Cover type
                 (if used), Mist suppressant (if used),  Ampere-hours,
                 Part type and  surface  area, and Type  of ventilation
                 system)

          * Emissions Information  (Exhaust  gas volumetric flow  rate,
                 Hexavalent chromium  concentration  at  control device
                 inlet,  Hexavalent  chromium mass emission rate at inlet,
                 Type  of  control  .device,  Ambient  temperature,  and
                 Duration of test)
7CQ

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Uncontrolled Emission Factor.Development
Review of the data from the EPA literature indicated that there
is  little relationship  between uncontrolled emissions and most
process factors.  The following combinations of data provided the
most  promising emission  factor correlations  for uncontrolled
Cr(VI) emissions:

      1. milligrams  Cr(VI) vs  ampere-hours
      2. milligrams  Cr(VI) vs  ampere-hours x bath area
      3. milligrams  Cr(VI) vs  plated area x time
      4. milligrams  Cr(VI) vs  ampere-hours x bath volume x bath
         Cr(VI) concentration
      5. milligrams  Cr(VI) vs  ampere-hours x bath volume

Due  to  qualitative  differences  in conditions  between plants,
development of  an overall  predictive  model  using all test data
was not successful.  Attempts  with multiple variable regression
using  the  entire  data  set  failed to  produce  any  attractive
correlations.

However, some   correlations  were more  notable.   Uncontrolled
emissions appeared to be  directly  correlated with ampere-hours
when data from single facilities were  used.  Combination of data
from the eight EPA facilities  and the two facilities visited by
our project team suggested a common linear relationship between
Cr(VI) emission rate and  ampere-hours.   However, this combined
model exhibits considerable scatter.

The emissions rate data was  correlated  with  the product of the
ampere-hours and  the plating bath  volume (combination number 5
mentioned above).  The  results are  presented  in Figure 1.   The
observations are segregated .into two groups which a're defined by
the following relations:

          Cr = 49,000 + 0.0016 x Amphr x Vol           (1)

          Cr = 2,900 + 0.00065 x Amphr x Vol           (2)

  in which  Cr = mass emission of hexavalent chromium
                prior to control devices (milligrams)
        Amphr = power consumption (Ampere-hours)
          Vol = plating tank volume (Liters)

Factors to explain the discrimination between the two groups have
not been identified.  The  more conservative model  (Equation 1;
predicting  higher emission rates)  could be  used for  general
prediction   of   hexavalent  chromium emissions.    An  approach
incorporating the entire data set is still being investigated.
                                                                     769

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      Figure 1 - Uncontrolled Stack Emissions For Hexavalent Chromium
                350
         O

         1
         V.
         .Q)


         1
•9
*5j

I
to
fro
cc
    CO
   ~
_c
I-
                                                   D
                        50   100   150   200   250  300   350
                          Ampere-Hours x Bath Volume (Ah-Liters)
                                       (Millions)
                                                       400
      Fugitive Results - Hexavalent Chromium
      SamplingDevice
      The fugitive emission  samples  were collected using  a sampling
      train based  on the  EPA  EMTIC CTM-OQ6  Method  .   This  method
      applies  to the determination of Cr(VI)  in  stack emissions from
      decorative and hard chrome plating facilities.  The approach used
      in the  EMTIC  Method  involves  collection of  Cr(VI)  from  a
      ventilation stack into  a one-  quart  glass  impinger.    This
      impinger contains  250  ml of- a 0.1  N sodium hydroxide  buffer
      solution to trap and  stabilize the Cr(VI) that is collected.   A
      second impinger in series is  filled with a desiccant to capture
      any moisture prior to the air entering the dry gas meter.

      The impinger sampling  method  used in this study  differed from
      that  of  the EMTIC  Method in five  major ways:

           (1)  The sampling  inlet  was  fixed  at 52  inches  from  the
      ground in order to  approximate breathing  zone  concentrations,
      rather  than  attached  to   a  probe  which   measured   stack
      concentrations;
770

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     (2) Two glass impingers with alkaline buffer  solution were
used in series,  rather  than only one, to ensure capture  of all
sampled Cr(Vl) mist;
     (3) The  dry gas meter was placed  between  the last  glass
impinger  and  the  critical  orifice  to  prevent  pump  oil  from
fouling the  dry gas  meter, rather  than last in  the  sampling
train;
     (4) The dry gas meter was no longer exposed to  ambient air
pressure so a  temperature .gauge and pressure gauge were placed at
the meter inlet and outlet, respectively; and,
     (5) No ice  bath  was  used  for the impingers since  moisture
condensation in the ambient air was not  measured.

A schematic of  the sampling train  is shown  in  Figure 2.   The
components of  the train  were  available commercially but  some
fabrication was required.   A sturdy wood support  housing made of
pine 2  x  4's  and  2  1/2  inch  wood  screws  was  designed  to  be
compact and portable  to accommodate  the needs  of  the  project.
Figure 3 shows a photograph of  one  of the five sampling  trains
constructed at the University of Central Florida  Department of
Civil and Environmental Engineering.

              Figure 2 - Sampling Train  Schematic
                                   Thermometer
                                                   Pressure Gees
                                                     o
                                            Dry Gcs
                                            NX -s t & r-
                            Silico Gel
             GIG:
                   I fr\ p i r~i 
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                   Figure 3 - Photograph of Sampling Train
       Sampling Criteria
       Air  was drawn  through the impingers using 1/4 hp vacuum pumps.
       To sample Cr(VI), a constant sampling rate of 0.67 acfm for a 2
       to 3 hour period was used.  This sampling rate was controlled by
       use  of a critical orifice downstream of  the sample line.

       The  system was designed to achieve a liquid phase concentration
       of Cr(VI) in the  scrubber solution of  0.4 to 1.0 mg/L, well in
       excess  of the  0.016  mg/L detection  limit.    For  the  stated
       conditions, detection limits of air phase  concentrations were
       less than 10 ug/m .

       Sample Analysis and QA/QC
       Kexavalent chromium was  analyzed  in accordance  with Standard
       Methods  Method 3500-Cr  D  (17th Edition) .    The Cr(VI)  ions
       captured in the alkaline  scrubber  solution  were complexed with
       diphenylcarbazide  solution.    A  colorimetric  procedure  was
       performed in the field within 24 hours of sample  collection.  The
       dry  gas  meters were  calibrated using a  wet  test meter.   The
       entire sampling train  was tested for leaks before each operation.

       Samples were stored and transported in plastic containers which
       were thoroughly cleaned in nitric acid and rinsed with distilled
       water before use.  The analytical program included the following
       quality control checks:   Duplicates, spikes,  field blanks,  and
       check standards.
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Field Sampling - Plant 1
The  facility at  this  site  processed large  industrial  rolls.
Plating  activity  occurred  in  only two  of three  chromic  acid
tanks,  but  ambient  air samplers  were  placed  near  all  tanks
because  they were still heated and ventilated.   One operating
tank was covered by a steel plate except for top openings through
which  cylinders  to  be plated could  be inserted.    Forced
ventilation  was used  on three sides of  the tank,  but the tank
cover allowed air to enter only the  airspace above the liquid
through  the  top  openings mentioned.   Ventilation  of all  tanks
occurred by  use of  a duct system which  was routed to a single
outlet stack.  A sampler was placed  both  upstream and downstream
of 'expected  air  currents  across  this tank.   One  sampler was
placed away  from  all tanks  to  allow measurement of  background
concentrations.   The other two tanks  were not  covered,  even
during plating  operations,  and one  sampler was placed at the
"downwind" side of each of these tanks.

FieldSampling - Plant 2
The facility at the second  site processed aircraft engine parts.
The shop had five plating  tanks near the  west  wall of a  large
room.   The  room  was sectioned  off for ventilation purposes.
During normal operations, all plating tanks-were covered with a
plastic sheet in an effort to stop fugitive air emissions.   The
tanks were ventilated  by a  duct system  which was  routed  to a
single outlet stack.  Four samplers were placed next to four of
the most active plating tanks and a  fifth sampler was placed east
of the tanks for background sampling.  Ambient air sampling was
done at one tank with and without the plastic cover in place.

Room Air FlowRates
Determination of mass emission rates  (stack and fugitive)  were
made using the measured ambient air concentrations and measured
air flow rates.   Air velocity measurements were  completed for
doorways and windows which represented inlet air sources to the
plating room at each  of the two facilities we  studied.   These
measurements showed that a negative pressure in the room resulted
in a  net air flow  entering the room  through all  windows and
doors.  All air flow leaving the room was through the stack and
ventilation system.   For these  circumstances, fugitive emissions
would eventually be re-captured into the  stack or deposited onto
surfaces (floors,  walls)  in the plating room.

Air flow rates  in the plating  facilities  were  determined  with
three separate techniques:

       1. Estimation based on  engineering  specification of the
          ventilation system, not including the stack which was
          sampled;
       2. Velocity measurements in  the sampled stack; and,
       3. Velocity measurements at  windows  and doors.
                                                                     773

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       Table 1 below shows results of the airflow measurements made at
       the two plants visited by our project team.

                 Table 1  - Air Flow Rates at Studied Plants
Plant
1
2
Air Flow Rates (scfm)
Inputs
Windows/Doors
14500
26500
Outputs
Stack
6100
13460
Ventilation
9000
13350
Total
15100
26810
       As shown in  Table 1, it  can be concluded  that the total  air
       exchange in   the  rooms   is  essentially  equal  to  the  total
       ventilation flow rate.   Thus, escape of any Cr(VI)   mists into
       the room air  will  either fall out in the room or will eventually
       be carried  out through the stack or room ventilation system.

       CrfVI)  Sampling Results
       Four sampling runs were  performed at each site; two  on  each  of
       the two days  of sampling that occurred  at  each  location. •  Based
       on an assumed production schedule of 2000 hours per year for both
       plating facilities,  a final  summary of the average  results  of
       stack  and fugitive sampling is provided in Table 2  below.

         Table 2 - Fugitive and Uncontrolled Stack Cr(VI)  Results
Plant
1
2
Cr(VI) Cone
(ug/std cu m)a
Stackb
10040
414
Fugitive
< 4
< 6
Annual Emissions
(Ib Cr (VI) /year)
Stackb
460
41.7
Fugitive
< 0.5
< I
                 amicrograms per standard cubic meter.
                 bStack emissions are prior to reaching the control
                  device.

       Fugitive  emissions were more difficult  to quantify than  stack
       emissions  for  the  following reasons.

            1. Fugitive  sample results were generally below detection
       limits.    This  led to  the  use  of  a conservative  approach  in
       calculating ambient  Cr(VI)   concentrations.   The subsequent
       analysis  is predicated on air  concentrations  at the detection
       limit of 4  ug/std  cu m  in Plant  1 and 6 ug/std cu m in Plant  2.
774

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It  is  believed that actual concentrations  were much less than
this limit, thus the resulting calculations would yield a decided
overestimate of the actual result.

     2. Fugitive emissions are collected along with a  portion of
room air via the facility ventilation system and may  be carried
outside through other parts of the plant via stacks which have no
control devices.  However, some of the Cr(VI) mists in the room
air are captured by  the plating room stack ventilation  system and
are  incorporated into  stack  emissions.   The  calculations  of
fugitive emissions  shown  in Table  2  were based on an extremely
conservative approach  in  which the  total  room ventilation was
assumed to contribute to the fugitive emission rate.

For  the  stated  conditions,  the annual  emission rates  due  to
fugitives from Plants 1 and 2  are < 0.5  Ib/year and <  1 Ib/year,
respectively.   The  values for both  facilities are  believed to
greatly exceed  actual  fugitive releases  for  the reasons cited
above.  Even so, for the purposes of completion of Form R, this
estimate  of the  fugitive releases  would  be  reported  in  the
minimum category (zero to one pound per year).

Fugitive emissions from Plant  1 were  negligible in comparison to
stack  mass  flow rates.    In  fact,  for  a   typical  scrubber
efficiency of 99%,  stack  exit emissions of Cr(VI)  would be 4.6
Ib/year for plant 1, which is still an order of magnitude greater
than the corresponding fugitive emissions.  The only fugitive air
sample which was above detection limits was obtained immediately
downstream from an uncovered process  tank which experienced loss
of vapors over the unventilated end of the tank.

The  results  from Plant  2 are  in general  agreement with  the
findings from the first facility; fugitive releases do  not appear
to represent a  significant portion of the total air emissions.
Only   one   ambient   sampler   showed   a  measurable   Cr(VI)
concentration.   This result was obtained near an operating tank
during  testing  with  the  plastic   covering  removed.     The
inexpensive  plastic  sheets  covering  the  tanks  appeared  to
minimize emissions as suggested by the employees.

Cgncl_us_iQ.ns
While  the' EPA  has  done  extensive  work  in  the last  decade  to
quantify  controlled  and  uncontrolled  stack   emissions   of
hexavalent  chromium from hard  chrome  plating  facilities,  no
documented efforts were made to measure fugitive emissions.  This
study represents an assessment of  airborne fugitive  hexavalent
chromium concentrations at these  facilities.   In an  effort  to
develop a  model for stack emissions  of Cr(vT) , EPA  data were
reviewed and a  correlation for chromium emissions was reported
versus ampere-hours  and plating bath volume.
                                                                    775

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       A modification  of a  stack  sampling train  was constructed  to
       accommodate fugitive sampling efforts  made  at two hard  chrome
       plating facilities.  The levels found at both site,  for the most
       part,  were below detection limits  of 4  ug/std cu m  and 6  ug/std
       cu m  for  the  1st and  2nd plant,  respectively.    The  annual
       emission rates from Plants 1 and 2 are < 0.5  and < 1  Ib  Cr(VI)
       per year,  respectively.  For the purposes of completion of Form
       R,  these estimates of the fugitive releases would be reported in
       the minimum category  (zero to  one  pound per  year).

       Acknowledgements
       The information  in this article has been funded wholly or in part
       by the U.S. Environmental  Protection Agency  under Cooperative
       Agreement CR-817586-Q1-0 to the AESF.  Financial support from the
       AESF is also gratefully acknowledged..  This article  has not been
       subjected  to  the  Agency   peer  review process  and  does  not
       constitute an  endorsement  by or necessarily  reflect the view of
       the Agency.

       References
       1.   U.  S.  Environmental Protection  Agency,  "Health Assessment
           Document  for Chromium:  Final Report,"  EPA-600/8-83-
           014F,  Environmental Criteria  and Assessment Office,
           Research  Triangle Park, NC, 1984.

       2.   U.  S.  Environmental Protection  Agency,  "Chromium  Emissions
           from Chromium Electroplating  and Chromic  Acid Anodizing
           Operations-Background  Information  for Proposed Standards,"
           Volume I, NESHAP  Preliminary  Draft, Office of Air Quality
           and Standards, Research Triangle Park,  NC, Dec. 1990.

       3.   U.  S.  Environmental Protection  Agency,  "Draft Modified
           Method 13B  - Determination of Hexavalent  Chromium
           Emissions from Decorative and Hard Chrome Electroplating,"
           Environmental Monitoring Systems Laboratory, Office  of
           Research  and Development, Cincinnati, OH, Dec. 1990.

       4.   U.  S.  Environmental Protection Agency,  "Determination  of
           Chromium  Emissions from Chromium Electroplaters,"  EMTIC-
           006  Conditional Test Method, Prepared by  Frank Clay,
           Emission Measurement Branch Technical Support Division,
           OAQPS, EPA,  8 Nov. 1990.

       5.   American  Public Health  Association, "Standard Methods  for
           the  Examination of Water and Wastewater," 17th Edition,
           Washington,  DC, 1991.
776

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completi
1. REPORT NO.
  EPA/600/A-93/069
                              2.
                                                            3.
4. TITLE AND SUBTITLE
                                                            5. REPORT DATE
   ATMOSPHERIC RELEASES OF HEXAVALENT  CHROMII
      HARD CHROMIUM PLATING OPERATIONS .
  FROM
              6, PERFORMING ORGANIZATION CODE
           M> s> Hallj 0> D> DietZ5  c>  David cooper,
           R, L. Wayson, and D.  Bauman
                                                            8. PERFORMING ORGANIZATION REPORT NO,
9, PERFORMING ORGANIZATION NAME AND ADDRESS
   University of Central Florida
   4000 Central Florida Boulevard
   P.O. Box 25000
   Orlando, FL  32816-0450
                                                            10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.

                 CR-817586-01-0
12. SPONSORING AGENCY NAME AND ADDRESS
   Risk Reduction Engineering Laboratory—Cincinnati, OH
   Office of Research and Development
   U.S.  Environmental Protection Agency
   Cincinnati, Ohio  45268
              13. TYPE OF REPORT AND PERIOD COVERED
              Presentation & Proceedings
              14, SPONSORING AGENCY CODE
                  EPA/600/14
15. SUPPLEMENTARY NOTES
                      Project Officer  —  Mark J.  Stutsman, (513) 569-7776
 Presented at American Electroplaters  &Surface Finishers Society's Annual SUR/FIN  Conf,
 held in Atlanta, GA on June 22-25,  1992.   Proceedings pp. 767-776.	
16. ABSTRACT
      The University of Central  Florida Department of Civil and Environmental
 Engineering is investigating methods  for improved estimation of chemical  releases
 which require reporting under provisions of SARA Title III (Toxic  Release Inventory,
 Form R).
      This paper describes results  from a research project initiated  in  the Fall  of
 1990.  The preliminary objective was  to help the surface finishing industry to
 identify and solve specific problems  with completion of Form R.  A problem would
 generally be defined as a combination of a process (e.g., hard chrome plating) and a
 release (e.g., fugitive air releases  of hexavalent chromium).  It  was concluded that
 the  majority of environmental releases (water and sludges) are subject  to some form
 of monitoring in conjunction with  an  operating permit.  Accordingly, monitoring data
 is usually available to support completion of Form R.  The principal exception to
 this generalization concerns air emissions,  particularly fugitive  emissions.
      The initial process selected  for field characterization was hexavalent chromium
 releases from hard chrome plating.  The sampling effort involved simultaneous
 quantification of fugitive emissions  and emissions through existing  tank  ventilation
 systems into the stack.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b. IDENTIFIERS/OPEN ENDED TERMS
                           c. COSATi Field/Group
  Toxicity
  Chrome
  Plating
Toxic  Release Inventory
Hexavalent Chromium
 8. DISTRIBUTION STATEMENT

  RELEASE TO PUBLIC
19. SECURITY CLASS (This Report/
  UNCLASSIFIED
                                                                          >1. NO. OF PAGES
12
20. SECURITY CLASS (This page I
  UNCLASSIFIED
                           22. PRICE
EPA Form 2220-1 (R»v. 4-77)   PREVIOUS EDITION is OBSOLETE

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