HOW WILL I DEMONSTRATE COMPLIANCE?

TABLE 5-2. METHODS USED TO ESTABLISH OPERATING PARAMETER VALUES

Monitored parameter	Applicable air pollution control systems	Method used to establish acceptable values
Pressure drop	Composite mesh-pad systemPacked-bed scrubberFiber-bed mist eliminator	1. Range of values from multiple performance tests or2. +1 inch of H2O column about the average pressure drop measured during three compliant test runs
Velocity pressure	Packed-bed scrubber	1. Range of values from multiple performance tests or2. +10 percent about the average velocity pressure measured during three compliant test runs
Surface tension	Wetting agent	1. Use 45 dynes/cm or2. Maximum surface tension measured during at least three compliant test runs
Foam blanket thickness	Foam blanketFume suppressant	1. Use 1 inch foam blanket thickness or2. Minimum foam blanket thickness measured during at least three compliant test runs

TABLE 5-3. SUMMARY OF ONGOING MONITORING REQUIREMENTS

Air pollution control system	Monitored parametera	Monitoring frequency
Composite mesh-pad system	Pressure drop across system	Daily
Packed-bed scrubber	Pressure drop across system	Daily
	Velocity pressure at system inlet	Daily
Packed-bed scrubber/composite mesh-pad system	Pressure drop across the mesh-pad system	Daily
Fiber-bed mist eliminator	Pressure drop across the mist eliminator	Daily
	Pressure drop across the control device located upstream of the fiber bed that prevents plugging	Daily
Wetting agent or combination wetting agent/foam blanket fume suppressants	Surface tension	Every 4 hoursb,c
Foam blanket-type fume suppressants	Foam blanket thickness	Every hourc,d
Fume suppressant/add-on control device	As identified above

^aAcceptable values for these monitored parameters are established during initial performance testing.

^bIf there are no exceedances of the maximum surface tension after 40 hours of operation, then the monitoring frequency can be decreased to once every 8 hours. If there are no exceedances for the next 40 hours, then the frequency can be decreased to once every 40 hours. If an exceedance occurs at any time after that, then the initial monitoring schedule (every 4 hours) must be resumed.

^cThe initial schedule must be resumed for every new tank solution.

^dIf there are no exceedances of the minimum foam blanket thickness after 40 hours of operation, then the monitoring frequency can be decreased to once every 4 hours. If there are no exceedances for the next 40 hours, then the frequency can be decreased to once every 8 hours. If an exceedance occurs after that, then the initial monitoring schedule (every hour) must be resumed.

There are three components to demonstrating compliance with the emission limits of this regulation:

• Initial performance testing
• Ongoing compliance monitoring
• Special compliance provisions
  

INITIAL PERFORMANCE TESTING

What is the purpose of the initial performance test?

There are two reasons to perform an initial performance test. First, an initial performance test is necessary to determine if the chromium emissions from the affected source are the same or lower than the emission limits set for the source. The emission limits for the different chromium electroplating tanks and chromium anodizing tanks were listed in Table 4-1. Second, the initial performance test establishes values or ranges of values for the air pollution control system operating parameters. Monitoring and recording these operating parameters during tank operation will give you an indication of whether or not you are in compliance with the emission limits.

Summary of testing requirements.

Except for the situations noted below, you will be required to perform an initial performance test. This test must be conducted by July 23, 1996 for decorative chromium electroplaters and by July 24, 1997 for hard chromium electroplaters and chromium anodizers.

However, sources that meet the following criteria do not have to perform testing:

• Decorative chromium electroplating tanks or chromium anodizing tanks that use a wetting agent and limit the surface tension of the bath to a maximum of 45 dynes/cm and
• Decorative chromium electroplating tanks that use a trivalent chromium bath.
  

A test plan that describes the proposed initial performance testing program should be developed prior to testing and may be requested by EPA. The test plan should describe the process to be tested, the conditions under which testing is to be conducted, the sampling locations, and the test methods to be used. Also, you must notify EPA in writing of your intent to conduct a performance test prior to the test. This notification is described in Chapter 6 of this guidebook.

The performance test report is prepared by the test contractor after testing has been conducted. The test report must contain the information listed in Table 5-1 and must be submitted to EPA as part of the reporting requirements described in Chapter 6 of this guidebook.

INFORMATION REQUIRED IN INITIAL PERFORMANCE TEST REPORT

• Process description
• Sampling location descriptions
• 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 and calibration procedures
• Raw data sheets for field sampling and field and laboratory analyses
• Documentation of calculations
• Any additional information required by the test method

Test methods. EPA Reference Method 306 or 306A, "Determination of Chromium Emissions from Decorative and Hard Chromium Electroplating and Anodizing Operations," must be used to determine chromium emissions from decorative or hard chromium electroplating tanks or chromium anodizing tanks. Detailed descriptions of these reference methods are located in Appendix A of part 63 of the Code of Federal Regulations. The EPA produced a videotape on stack sampling and monitoring entitled "Construction and Operation of the EPA Method 306A Sampling Train and Practical Suggestions for Monitoring of Electroplating and Anodizing Facilities" that is available to you for a nominal fee through North Carolina State University, Raleigh, NC by calling (919) 515­5875.

The California Air Resources Board (CARB) Method 425 may also be used to measure chromium emissions as long as the analytical requirements listed in the regulation are adhered to. Alternate test methods may also be used as long as they have been validated using EPA Reference Method 301.

EPA Reference Method 306B, "Surface Tension Measurement and Recordkeeping for Tanks Used at Decorative Chromium Electroplating and Anodizing Facilities'" must be used to determine the surface tension of electroplating and anodizing baths if you are complying with the surface tension limit rather than the emission limit.

Monitoring requirements. During performance testing, applicable air pollution control system operating parameters must be recorded. These operating parameters are determined by the air pollution control system you are using and are listed in Table 5­2. At the conclusion of testing, a range of acceptable values or a maximum or minimum value for these parameters can be established as described below.

For pressure drop measurements, the range can be established as the range of pressure drops measured during multiple performance tests, or as plus or minus 1 inch of water column about the average pressure drop measured during three compliant test runs (i.e., the source was at or below the applicable emission limit).

For velocity pressure measurements, the range can be established as the range of velocity pressures measured during multiple performance tests, or as plus or minus 10 percent about the average velocity pressure measured during three compliant test runs.

For surface tension, a maximum value can be established during performance testing, or you can forego testing (if you have a decorative chromium electroplating or a chromium anodizing operation) and accept 45 dynes/cm as the maximum surface tension value.

For foam blanket thickness, a minimum foam blanket thickness can be established during performance testing or the facility can elect to use 1 inch as the minimum foam blanket thickness.

Applicability of previous test results. If you have already conducted a performance test to obtain an operating permit in your State, the results of the testing can be used to demonstrate compliance with this regulation only if each of the following criteria is demonstrated:

• the appropriate test methods were used;
• the test was conducted under representative operating conditions;
• the test report contains the elements listed in Table 5-1;
• the test was conducted after December 1991; and
• you developed sufficient monitoring data to establish the operating parameter values that correspond to compliance with the emission limits.
  

If any of these criteria are not met, then you will have to retest.

ONGOING COMPLIANCE MONITORING

What is the purpose of ongoing monitoring? You must continue to monitor the operation of the air pollution control system to ensure ongoing continuous compliance with the emission limits. By monitoring and recording the appropriate air pollution control system parameters and comparing the monitored values to the range of values, maximum value, or minimum value established during the performance test, you and the enforcing agency can determine if you are in compliance with the emission limits.

How do I know if I am out of compliance with the emission limits? Monitored values that fall outside of the range of values established for pressure drop and velocity pressure, exceed the maximum surface tension, or fall below the minimum foam blanket thickness indicate that the tank is out of compliance with the emission limits (i.e., excess emissions). Table 5­3 summarizes the ongoing monitoring requirements including the monitoring frequency for the various air pollution control systems.

Can I decrease the monitoring frequency of monitored values? The monitoring frequency for pressure drop and velocity pressure cannot be changed. However, the frequency of monitoring surface tension and foam blanket thickness can be decreased. Figure 5­1 is a flowchart showing how the monitoring frequency can be decreased for a wetting agent, a combination wetting agent/foam blanket-type fume suppressant, or a foam blanket-type fume suppressant. The information in Figure 5­1 is also described in the footnotes to Table 5­3.

SPECIAL COMPLIANCE PROVISIONS

The regulation contains special compliance provisions for determining compliance with the emission limits under certain circumstances. These special compliance provisions are applicable in the following situations involving multiple tanks manifolded to one control system:

• The multiple tanks include a chromium electroplating or chromium anodizing tank among other tanks not affected by the regulation or
• The multiple tanks include chromium tanks performing different operations subject to different emission limits (e.g., hard chromium electroplating and anodizing) or hard chromium tanks subject to different emission limits (e.g., a new tank and an existing small tank), which may or may not be controlled with nonaffected sources.
  

In these situations, it would be very difficult to directly determine compliance with the emission limits in the regulation. Therefore, section 63.344(e) of the final regulation provides equations for verifying compliance with the emission limits in both of these situations.

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