Emissions revisions for electroplaters
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September 21, 2012
Emissions revisions for electroplaters

Following residual risk and technology reviews (RTR) required by the Clean Air Act (CAA), the EPA has issued significant amendments to its national emissions standards for hazardous air pollutants (NESHAP) for chromium electroplating; chromium anodizing tanks; steel pickling– hydrochloric acid (HCl) process facilities; and HCl regeneration plants.  The main amendment increases the stringency of the chromium emissions limits for chromium electroplating and chromium anodizing tanks.  Additional amendments include new housekeeping requirements to minimize fugitive emissions and the phaseout of perfluorooctane sulfonic acid (PFOS)-based fume suppressants.
California hard chrome rules
The NESHAPs for these source categories affect a large number of facilities.  According to the EPA, there are approximately 188 large and 394 small hard chrome electroplating facilities outside of California.  California has adopted regulations that essentially require facilities to install high efficiency particulate air (HEPA) filters in all hard chromium plants.  The EPA decided it is not necessary to go this extra step to satisfy the health protection provisions of the CAA.  The Agency also estimates that 517 decorative chrome facilities, 170 chromium anodizing plants, and 100 steel pickling plants will be affected by the amendments.
Emissions limits
The revised emissions limits are as follows:

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  • Large hard chromium electroplating facilities—the limit for existing sources is lowered from 0.015 milligrams of total chromium per dry standard cubic meter (mg/dscm) to 0.011 mg/dscm; the limit for new sources is 0.006 mg/dscm. 
  • Small hard chromium electroplating facilities—the emissions limit for pre-1995 sources is lowered from 0.03 mg/dscm to 0.015 mg/dscm; the limit for new sources is 0.006 mg/dscm.
  • Decorative chromium electroplating facilities—the emissions limit for existing sources is lowered from 0.01 mg/dscm to 0.007 mg/dscm; the limit for new sources is 0.006 mg/dscm. 
  • Chromic acid anodizing facilities—the emissions limit for existing sources is lowered from 0.01 mg/dscm to 0.007 mg/dscm; the limit for new sources is 0.006 mg/dscm.   

Existing housekeeping requirements have been modified by removing routine housekeeping measures from recordkeeping, adding that cleanup must be initiated within 1 hour of the spill, and allowing facilities to collect dragout using other methods when drip trays are not practical.
Other parts of the final rule modify and add testing and monitoring, recordkeeping, and reporting requirements for hard and decorative chromium electroplating and chromium anodizing tanks and revise regulatory provisions during periods of malfunction at these sources.  Regulations for steel pickling facilities have been modified to indicate that the emissions limits apply at all times, including during periods of start-up, shutdown, and malfunction.  Finally, for HCl regeneration plants, the EPA has eliminated an alternative compliance option that allows a facility to apply to its permitting authority for a site-specific alternative chlorine concentration standard.  The Agency states that it does not believe this option is consistent with the requirements of the CAA.
The compliance date for implementing the housekeeping requirements is March 19, 2013.  The compliance date for the revised emissions limits and surface tension limits is September 19, 2014.  The compliance date for eliminating the use of PFOS-based fume suppressants is September 21, 2015.
EPA’s amendments were published in the September 19, 2012, FR

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