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Chromium Electroplating and Anodizing NESHAP

Important note: This fact sheet covers the original Chromium Electroplating and Anodizing NESHAP. On September 15, 2012, a new final rule was became effective. The compliance dates for the new rule vary for different components of the rule (e.g., housekeeping, emission limits) and depend on whether the process is existing or new. To access the fact sheet for the new rule: click here.

On January 25, 1995, the U.S. Environmental Protection Agency promulgated the National Emission Standard for Hazardous Air Pollutants for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (Chrome NESHAP). Since then, the Chrome NESHAP has experienced several amendments. The Chrome NESHAP affects all facilities that use chromium electroplating tanks, regardless of size. Activities your facility must do to comply with the Chrome NESHAP are dependent upon the size of the operation and the type of process (hard, decorative, or anodizing).

NOTE: This fact sheet will only focus on the issues that hard chromium electroplaters need to address due to the chrome NESHAP.

The Chrome NESHAP is published in Title 40, Part 63, Subpart N of the Code of Federal Regulations (40 CFR 63).

In general, the Chrome NESHAP contains six requirements:

  1. Emission limits
  2. Work practice standards
  3. Performance testing
  4. Monitoring
  5. Recordkeeping
  6. Reporting

The specific requirements for each hard chromium electroplating tank depend on the type of tank, the rectifier capacity, the date of startup, and whether the facility is a major source or an area.

APPLICABILITY TO THE NESHAP

All chromium electroplating located at a facility performing hard chromium electroplating is subject to the NESHAP. However, a tank is exempt from the Chrome NESHAP if it meets one of the following conditions:

    • No chromium electroplating is actually taking place in the tank (e.g., rinsing tanks, etching tanks, and cleaning tanks).
    • No electrolytic process occurs in the tank (e.g., a chrome conversion coating tank where no electrical current is applied).
    • The tank is being used to conduct research or laboratory operations.

COMPLIANCE DATES

Existing tanks (initial startup on or before 12/16/93)

Existing chromium electroplating tanks had to comply with the Chrome NESHAP by January 25, 1997. All new chromium electroplating tanks with an initial startup after January 25, 1995, are required to comply with the Chrome NESHAP immediately upon startup.

EMISSION LIMITS

The Chrome NESHAP specifies emission limits that facilities can typically achieve by using a certain control and monitoring technique to reduce emissions. Table 1 lists the emission limits and the emission reduction technique that corresponds to each emission limit.

Chromium Plating Emissions Calculator

Table 1. Emission Limits and Corresponding Control Techniques

(On Sept. 19, 2014, revised emission limits take effect. Also, by Sept. 21, 2015, the use of PFOS-based fume suppressants must be eliminated, see new rule. )

AFFECTED TANK
EMISSION LIMITa
CONTROL TECHNIQUE
Large existing tanks and all new tanks 0.015 mg/dscm (6.6 x 10- gr/dscf) OR 35 dynes/cm with tensiometer 45 dynes/cm with stalagmometer Composite mesh-pad (CMP) system OR Fume suppressant (FS) that contains wetting agent
Small existing tanks 0.03 mg/dscm (1.3 x 10-5 gr/dscf) OR 35 dynes/cm with tensiometer 45 dynes/cm with stalagmometer Packed-bed scrubber (PBS) OR FS that contains wetting agent

a mg/dscm = milligrams per dry standard cubic meter of exhaust air; gr/dscf = grains per dry standard cubic feet of exhaust air; and dynes/cm = dynes per centimeter; b Small means that the facility has a maximum potential rectifier capacity of less than 60 million ampere-hours per year or an actual rectifier capacity of less than 60 million ampere-hours per year demonstrated by using nonresttable meters.

WORK PRACTICE STANDARDS

[On March 19, 2013, additional housekeeping requirements take effect.]

The Chrome NESHAP specifies that all facilities must prepare an operation and maintenance plan. When developing this plan:

    • Specify the operation and maintenance criteria for the tank, control technique, and monitoring equipment.
    • Provide a checklist to document the operation and maintenance of the tank, control technique, and monitoring equipment.
    • Incorporate work practice standards.
    • Include a step-by-step procedure for identifying and correcting malfunctions.
    • Specify procedures to be followed that will prevent malfunctions.

PERFORMANCE TESTING

[Note that the Revised Rule (Sept. 15, 2012) requires all facilities to demonstrate compliance with the new lower limits. Under certain circumstance, this can be achieved using previous performance test data. For more information, click here.]

Facilities subject to the Chrome NESHAP and demonstrating compliance with the 0.015mg/dscm for large and new tanks, and 0.03 mg/dscm for small existing tanks, must conduct an initial performance test to demonstrate compliance with the emission limit standard. Facilities opting to demonstrate compliance using the surface tension limit are not subject to initial performance testing requirements.

This is a one-time test. Performance tests for new tanks with a startup date after January 25, 1995, must be conducted within 180 days after startup. Facilities must notify their state agency or air quality district of the testing date at least 60 days before the test and must submit a testing protocol.

Facilities must conduct the initial performance test using certain test methods and procedures listed in the Chrome NESHAP. Most facilities hire a testing service to conduct the test; however, the Chrome NESHAP allows facilities to perform their own testing.

Following the initial performance test, a performance test report must be submitted to your state agency that contains the following information:

    • A description of the process
    • Descriptions of the sampling locations
    • Sampling and analysis procedures and any modifications to standard procedures
    • Test results
    • Quality assurance procedures and results
    • Records of:
      • Operating conditions during testing
      • Preparation of standards used during test
      • Calibration procedures
    • Raw data sheets for:
      • Field sampling
      • Field and laboratory analysis
    • Documentation of calculations
    • Any additional information required by the test method

This report must be submitted to your state agency within 90 days after your initial performance test.

MONITORING

Facilities must demonstrate continuous compliance by monitoring an operating parameter value for each control technique. This value links the control technique with the operating limit and is established during the initial performance test. Facilities must begin monitoring on the date of their initial performance test. Table 2 is a summary of the monitoring requirements.

Table 2. Summary of Monitoring Requirements

CONTROL TECHNIQUE
OPERATING PARAMETER
MONITORING FREQUENCY
OPERATING LIMIT
Composite mesh-pad (CMP) system
Pressure drop across the system
Daily
± 2˝ H2O
Packed-bed scrubber (PBS)
Inlet velocity pressure and Pressure drop across the system
Daily
± 10% and ± 1˝ H2O
PBS/CMP system
Pressure drop across the system
Daily
± 2˝ H2O
Fiber-bed mist eliminator
Pressure drop across the fiber-bed mist eliminator and Pressure across the upstream control used to prevent plugging
Daily
± 1˝ H2O
Wetting agent-type fume suppressant
Surface tension
Every 40 hours of operation
35 dynes/cm with tensiometer 45 dynes/cm with stalagmometer (see new limits that must be met by Sept. 19, 2014)
Foam blanket-type fume suppressant
Foam thickness
Hourly
Other control device
To be proposed by facility
To be proposed by facility

* dynes/cm = dynes per centimeter; and lbf/ft = pound-force per foot.

Surface Tension Monitoring

The surface tension shall be measured once every four hours during operation of the tank with a stalagmometer or a tensiometer as specified in Method 306B.

The time between monitorihng can be increased if there have been no exceedances. The surface tension shall be measured once every 4 hours of tank operation for the first 40 hours of tank operation after the compliance date. Once there are no exceedances during 40 hours of tank operation, surface tension measurement may be conducted once every 8 hours of tank operation. Once there are no exceedances during 40 hours of tank operation, surface tension measurement may be conducted once every 40 hours of tank operation on an ongoing basis until an exceedance occurs. The minimum frequency of monitoring allowed by this subpart is once every 40 hours of tank operation.

Once an exceedance occurs as indicated through surface tension monitoring, the original monitoring schedule of once every 4 hours must be resumed. A subsequent decrease in frequency shall follow the schedule laid out in the previous paragraph. For example, if an owner or operator had been monitoring an affected source once every 40 hours and an exceedance occurs, subsequent monitoring would take place once every 4 hours of tank operation. Once an exceedance does not occur for 40 hours of tank operation, monitoring can occure once every 8 hours of tank operation. Once an exceedance does not occur for 40 hours of tank operation on this schedule, monitoring can occur once every 40 hours of tank operation.

Once a bath solution is drained from th affected tank and a new solution added, the original monitoring schedule of once every 4 hours must be resumed, with a decrease in monitoring frequency allowed by the following the procedures addressed in the previous paragraph.

RECORDKEEPING

All facilities subject to the Chrome NESHAP must keep records to document compliance. The following records are required:

    • Inspection Records
    • Maintenance records
    • Malfunction records
    • Performance test results
    • Monitoring data
    • Excess emission records

Process records, including the following:

    • Operating time for each chromium electroplating tank.
    • For tanks using fume suppressants, the date and time that fume suppressants are added.
    • For small hard chromium tanks base dont he actual rectifier capacity, the actual rectifier capacity expended by month, and the total capacity expended semiannually for major sources and annual for area sources.

All records should be kept at the facility for at least five years. For sample recordkeeping forms, contact your state agency.

REPORTING

Every facility subject to the Chrome NESHAP must fulfill several reporting requirements. Table 3 summarizes what reports are required for each facility and the reporting deadline.

Table 3. Summary of Reporting Requirements

TYPE OF REPORT
FACILITIES THAT MUST REPORT
REPORTING DEADLINE
Initial notification report Existing tanks July 24, 1995
New and reconstructed tanks No later than 30 days after construction or reconstruction began
Performance test notification All facilities conducting initial performance tests At least 60 days before the test
Performance test results All facilities conducting initial performance tests No later than 90 days after the test
Notification of initial compliance status Facilities conducting initial performance tests No later than 90 days after initial performance test
Facilities not required to conduct initial performance test No later than 30 days after the compliance date
Ongoing compliance status report Major sources Complete twice a year, or four times a year if exceedances occur or if requested
Area sources Complete once a year, or two times a year if exceedances occur or if requested
Notification of construction or reconstruction All facilities As soon as practical before construction or reconstruction is planned to begin
Notification of when construction or reconstruction is commended All facilities Within 30 days of beginning constuction
Notification of actual startup All facilities Within 30 days of startup
Notification of process change All facilities No later than 30 days after the process change

 

 

 

 



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