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.

• Applicability to the Chrome NESHAP
• Compliance Dates
• Emission Limits
• Work Practice Standards
• Performance Testing
• Monitoring
• Recordkeeping
• Reporting

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:

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. )

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:

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:

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

* 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:

Process records, including the following:

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