A GUIDEBOOK ON HOW TO COMPLY WITH THE CHROMIUM ELECTROPLATINGAND ANODIZING NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS

CHAPTER 2

OVERVIEW OF THE REGULATION

The regulation affects all facilities that use chromium electroplating or anodizing tanks, regardless of size. How you are affected depends on the size and type (hard, decorative, or anodizing) of operation you have and the control technique(s) that you use to comply with the regulation. In general, the regulation specifies:

Each of these requirements is summarized below.

EMISSION LIMITS

The regulation specifies emission limits, expressed as a concentration of chromium in milligrams per dry standard cubic meter of exhaust air (mg/dscm) and that are based on the use of a certain control technique. However, you may use another control technique as long as the level of control is the same or better. These emission limits apply during tank operation only. The emission limits and the control techniques used as the bases for these limits are:

WORK PRACTICES

The regulation specifies work practice standards to ensure that air pollution control systems and monitoring equipment are being properly maintained and operated. The work practice standards require that most facilities develop an operation and maintenance (O&M) plan for the facility. Additional work practice requirements include quarterly inspections of control devices, ductwork, and monitoring equipment.

INITIAL PERFORMANCE TESTING

Initial performance testing is required (with some exceptions noted below) to demonstrate that you are meeting the emission limit for your type of operation. This is a one-time test. However, sources that meet the following criteria do not have to perform the initial test:

The regulation contains test methods (EPA Reference Methods 306 and 306A) for measuring the chromium concentration discharged to the atmosphere.

ONGOING COMPLIANCE MONITORING

Continuous compliance with the regulation is demonstrated through ongoing compliance monitoring. Monitoring of specific operating parameters that affect the performance of the particular control technique you are using is required to ensure continuous compliance with the emission limits. Therefore, the monitoring requirements vary depending on the type of control technique that you use.

If you use an add-on air pollution control device that is specified in the regulation, you must monitor the pressure drop across the unit daily. If you use a packed-bed scrubber, you must also monitor the velocity pressure (i.e., the velocity of the gas stream at the inlet of the unit) daily. The surface tension of the bath or the foam thickness must be monitored if you use wetting agents or foam blankets, respectively. The regulation contains a test method for measuring the surface tension of the bath (EPA Reference Method 306B). If you use a control system not specified in the regulation, you must determine the appropriate parameter(s) to monitor and get EPA approval.

RECORDKEEPING

The regulation requires sources to keep records to document compliance with the regulation. The required documentation includes: (1) inspection records; (2) equipment maintenance records; (3) records of the occurrence, duration, and cause of excess emissions (see Chapter 5 for an explanation of excess emissions); (4) performance test results; and (5) monitoring data. All records must be kept for 5 years. If you operate a decorative chromium electroplating tank that uses a trivalent chromium bath, you only need to keep records of bath component purchases.

REPORTING

The extent and frequency of reporting depends on the type and size of your source. The regulation requires an initial notification that you are subject to the regulation, a notification of performance testing, and a report of the performance test results and compliance status after the test. In addition, you must prepare reports that contain information on the ongoing compliance status of your facility. If you operate a decorative chromium electroplating tank that uses a trivalent chromium bath, you only need to submit the initial notification and an initial compliance status report.


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