Chromium NESHAP for Decorative and Hard Chromium Electroplating and Chromic Acid Anodizing.

Introduction

On September 15, 2012, the U.S. Environmental Protection Agency (EPA) finalized a rule that tightens air emission standards for chromium electroplating and anodizing operations. Facilities that operate decorative or hard chromium plating processes or chromic acid anodizing processes must be in compliance with the new rule over a phased in time period beginning in March 2013.

The new requirements which are summarized below include:

• housekeeping requirements
• revised emission limits and surface tension limits,
• a ban on the use of PFOS-based fume suppressants,
• modified and additional monitoring, recordkeeping and reporting requirements, and
• revisions to previous provisions related to emissions during periods of malfunction.

The full text of the new rule can be found in the Federal Register. [For completeness, see both the proposed rule published on February 8, 2012 and the final rule published on September 15, 2012.]

For a STERC fact sheet covering the original Chromium NESHAP, click here.

Housekeeping Requirements

The following housekeeping requirements must be implemented by March 19, 2013:

• storage requirements for any substance that contains hexavalent chromium as a primary ingredient;
• controls for the dripping of bath solution resulting from dragout;
• splash guards to minimize overspray and return bath solution to the electroplating or anodizing tank;
• a requirement to promptly clean up or contain all spills of any substance containing hexavalent chromium;
• requirements for the routine cleaning or stabilizing of storage and work surfaces, walkways, and other surfaces potentially contaminated with hexavalent chromium;
• a requirement to install a barrier between all buffing, grinding, or polishing operations and electroplating or anodizing operations; and
• requirements for the storage, disposal, recovery, or recycling of chromium-containing wastes.

More details on the housekeeping requirements are explained in the 2010 proposal and in the Response to Comments (RTC) document.

Revised Emission Limits and Surface Tension Limits

The previous and new emission limits are shown in Table 1. The new limits must be met by September 19, 2014.

Table 1. Comparison of Previous and New Emission Limits

Type of Process	Previous Emissions Limit	New Limit
Decorative Chromium
Existing sources	0.010 mg/dscm	0.007 mg/dscm
New Sources	0.010 mg/dscm	0.006 mg/dscm
Chromic Acid Anodizing
Existing sources	0.010 mg/dscm	0.007 mg/dscm
New Sources	0.010 mg/dscm	0.006 mg/dscm
Hard Chromium Plating
Existing sources (small)	0.030 mg/dscm	0.015 mg/dscm
New Sources (small)	0.015 mg/dscm	0.006 mg/dscm
Existing sources (large)	0.015 mg/dscm	0.011 mg/dscm
New Sources (large)	0.015 mg/dscm	0.006 mg/dscm

Notes:

1. mg/dscm = milligrams per dry standard cubic meter of exhaust air.
2. New source means an affected hard chromium electroplating tank, decorative chromium electroplating tank, or chromium anodizing tank, the construction or reconstruction of which commenced after February 8, 2012.

Facilities must demonstrate compliance with the new limits by conducting a performance or stack test. Facilities may use a previous performance test to demonstrate compliance with the new emission limits, provided that:

• the test was conducted after January 25, 1995,
• the source is using the same emission controls that were used during the compliance test,
• the source was operating under conditions that are representative of the conditions under which the source was operating during the compliance test, and
• the test was based on approval from a permitting authority.

For decorative and hard chromium electroplating operations that choose to monitor and demonstrate compliance by measuring the surface tension of the bath, the new limits are:

• 40 dynes/cm if measured by stalagmometer,
• 33 dynes/cm if measured by tensiometer.

Ban on Use of PFOS-based Fume Suppressants

The new rule contains a requirement to phase-out the use of perfluorooctane sulfonic acid (PFOS) based fume suppressants by September 21, 2015.

Modified and Additional Monitoring, Recordkeeping and Reporting Requirements

Regarding the monitoring and testing requirements, EPA revised the compliance provisions for multiple sources controlled by a common add-on air pollution control device, clarified that testing can be performed by either Method 306 or Method 306A, revised Method 306B to clarify that the method also applies to hard chromium electroplating tanks and include procedures for checking the accuracy of, and cleaning of, a stalagmometer.

The final rule amendments also require owners and operators of affected facilities to submit electronic copies of required performance test reports to EPA’s WebFIRE database through an electronic emissions test report structure called the Electronic Reporting Tool (ERT). The ERT generates an electronic report which would be submitted using the Compliance and Emissions Data Reporting Interface (CEDRI). The submitted report will be transmitted through EPA’s Central Data Exchange (CDX) network for storage in the WebFIRE database. The requirement to submit performance test data electronically to EPA applies only to those performance tests conducted using test methods that are supported by the ERT.

Revisions to Previous Provisions Related to Emissions During Periods of Malfunction

EPA added a provision to provide an affirmative defense against civil penalties for violations of emission standards caused by malfunctions, as well as criteria for establishing the affirmative defense, which is the same affirmative defense provision EPA has proposed or promulgated in several other recent NESHAP rules.

More Resources

Rule and Implementation Information for Chromium Electroplating. EPA's Technology Transfer Network (TTN). Includes links to background documents and fact sheets.

Chromium Plating Emissions Calculator. STERC supported on-line tool.

Contact EPA to ask a question.