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Compliance and Technical Assistance Program

CTAP > Featured Topics > January 2013: Amendments to the Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks National Emission Standards for Hazardous Air Pollutants (NESHAP), 40 CFR 63, Subpart N January 2013: Amendments to the Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks National Emission Standards for Hazardous Air Pollutants (NESHAP), 40 CFR 63, Subpart N

Definitions:

  • Existing: Construction or reconstruction which commenced on or before February 8, 2012.
  • New: Construction or reconstruction which commenced after February 8, 2012.

Surface Tension

Fume suppressant and reductions in maximum surface tension:

September 21, 2015: Additions of Perfluorooctane Sulfonic Acid or Perfluorooctane Sulfonate (PFOS) to any chromium electroplating and/or anodizing tank are prohibited after this date. EPA can grant a one year extension from this date to assist with compliance.

  • Stalagmometer: reduced from 45 to 40 dynes/cm
  • Tensiometer: reduced from 35 to 33 dynes/cm:
    • September 19, 2014: existing operations
    • Upon startup: new or reconstructed operations

Emission Limit Reductions:

  • September 19, 2014: existing operations
    • Open & enclosed hard chromium electroplating tanks
      • Large: reduced from 0.015 to 0.011 mg/dscm
      • Small: reduced from 0.030 to 0.015 mg/dscm
    • Decorative/Anodizing – reduced from 0.010 to 0.007 mg/dscm
  • Upon startup - new operations:
    • Hard – 0.006 mg/dscm
    • Decorative/Anodizing – reduced from 0.010 to 0.006 mg/dscm

Performance Test:

A facility which conducted a performance test after January 25, 1995 which now operates using the same emission controls under the same operating conditions as present at the time of the test would not be required to retest.

Changes to Recordkeeping:

In addition to maintaining surface tension measurement records and wetting addition records, the fume suppressant manufacturer and product name are now required as well.

Include Best Management Practices into your O&M Plan

Put into practice no later than March 19, 2013:
  • Store & Transport in closed containers; contain within an enclosure.
  • Preventive measures: Drip trays, contain & return or collect & treat.
  • Remove excess solution over tank.
  • Separate from buffing, grinding and/or polishing using a barrier (e.g., plastic strip curtains).
  • Begin cleanup within one hour of spill other than containment areas.
  • Clean surfaces every seven days or forty hours of operation, whichever is later - storage and open floor areas; walkways around tank. Choose one or more of the follow methods:
    • HEPA Vacuuming,
    • Hand-wiping with damp cloth,
    • Wet mopping,
    • Rinse using potable water and collect in a treatment system,
    • Apply non-toxic dust suppressant.

Affirmative Defense to violating standards during startup, shutdown and malfunction:

The following information is required to support a claim of Affirmative Defense:

  • Frequency, amount & duration of malfunction,
  • Time needed to make repairs,
  • Steps taken to minimize impact,
  • Nature of malfunction, and
  • Root cause analysis.