CHROME PLATING (HEXAVALENT)
Last adopted: July 17, 1991
Original Chapter adopted in 1991 (some of the information contained in this chapter may be outdated).
1. DESCRIPTION
This chapter covers the permitting of hexavalent chrome plating operations. These operations fall into three general categories: decorative chrome plating, hard chrome plating, and hard chrome anodizing. All of these processes emit hexavalent chromium in particulate (mist) form. Hexavalent chrome has been identified as a toxic air contaminant (human carcinogen) with no identifiable threshold for health effects. Any facility emitting hexavalent chrome must undergo the Authority to construct/Permit to Operate process as well as the District's air toxics health risk screening (or risk assessment) procedure.
In emissions potential, the order is 1) hard chrome plating, 2) hard chrome anodizing, 3) decorative chrome plating. Each of these will be outlined in turn.
2. APPLICATION CONTENTS
A. Data Forms
The following forms must be completed by the person submitting an applications (these forms are used by the District to characterize the type of process, size, flow rates, abatement devices, and exhaust stacks of the system):
Form P101-B: Application for Authority to Construct and Permit to Operate Industrial Sources
Form P-105: Small Business Certification (if applicable)
Form G: General Air Pollution Source
Form A: Abatement Device
Form P: Emission Point
B. Additional Information/Forms
Narrative description of operation.
Drawings, equipment specifications, and if available, manufacturers literature.
Emission source test results from a chrome plating or anodizing facility with the same or similar type of design.
Site plan and plot plan, with dimensions.
Copies of Material Safety Data Sheets (MSDS) for each material.
Information on whether the plant is located within 1,000 feet of the outer boundary of a school.
Risk Assessment Analysis: Request for information form if a preliminary toxic risk screen is required.
Stack parameters (height, flow rate) for vented machines (needed for toxic evaluation)
Maximum feasible throughput: Maximum annual throughout in amp-hrs which the facility is willing to live with as an enforceable permit condition. This limit determines which control category the facility must comply with.
3. COMPLETENESS
The following information is needed to make this determination:
A. All Authority to Construct and/or Permit to Operate fees must be paid.
B. All data forms listed in Section 2A must be completed by the applicant. In addition, the other information requested in Section 2B must be submitted when applicable.
C. Any additional information needed to calculate emissions.
D. Any additional information needed to complete a toxics risk assessment, if applicable.
4. REGULATIONS
A. Hexavalent chrome plating operations are subject to the following regulations:
Regulation 1: General Provisions
Regulation 2: Permits
Regulation 3: Fees
Regulation 11: Hazardous Pollutants
B. Air Toxics Policy: This policy is applicable to any source that emits any identified toxic chemical listed in the Air Toxic Screening Policy. Any source that emits a toxic chemical below its trigger level, or with a risk of 1 X 10-6 or less is considered a nonsignificant risk. If the TBACT level of control is employed, a risk of 10 X 10-6 or less is considered acceptable. Risk screens are conducted by the Toxics Section after the Permit Engineer provides the needed information to the Risk Screen Evaluator. The information required for the screen is listed on the Request for Information; Risk Screening Analysis form (attached). For TBACT explanation see Sections 5 and 6, following.
C. Public Notification within 1000 ft of school: Reg 2 Rule 1 Section 412 requires the APCO to prepare and distribute a public notice to the parents of children in any school within 1000 ft from the outer property lin of the proposed new or modified source. This form shall be distributed at least 30 days prior to the date final action on the application is to be taken by the APCO.
5. ABATEMENT EQUIPMENT
A. Decorative Chrome Plating: Acceptable control equipment for control of emissions from decorative plating facilities include the following methods: Note: each of the following methods constitute TBACT for the control of emissions from decorative chrome plating facilities.
1. Mist suppressant foam maintained in the tank in a manner which has been demonstrated to the satisfaction of the APCO to reduce emissions of hexavalent chromium by 95 percent or more relative to emissions when a mist suppressant is not used.
2. A layer of plastic balls continuously maintained in the tank is a manner which has been demonstrated to the satisfaction of the APCO to reduce emissions of hexavalent chromium by 95 percent or more relative to emissions when plastic balls are not used.
3. Any equivalent method that is demonstrated to the satisfaction of the APCO to reduce emissions of hexavalent chromium by 95 percent or more relative to emissions without control.
B. Hard Chrome Plating or Anodizing: Acceptable methods for the control of emissions of hexavalent chromium form hard chrome plating or anodizing operations include any process, procedure, method or appurtenance that can be demonstrated by District approved source test to meet the hexavalent chrome emission standard specified in Section 6.
6. STANDARDS
A. Standards that must be met before a permit can be issued:
Regulation 11 Rule 8: Hazardous Pollutants -- Hexavalent Chromium
1. General Requirements-All Chrome Platters
a. Section 11-8-501 (Usage Records): All chrome plating or anodizing facilities must keep monthly records of current applied to the bath integrated over time.
b. Section 11-8-503 (Reporting): All chrome plating or anodizing facilities must submit records of current consumption to the District on an annual basis.
2. General Requirements-All Hard Chrome Platters or Anodizers
a. Section 11-8-330 (Stack height/velocity): A person shall not operate a source subject to Section 11-8-310 (hard chrome platter or anodizer) unless all exhausted emissions are emitted through a stack no less than 10 meters above grade at a velocity of no less than 10 meters/second.
b. Section 11-8-403 (Compliance demonstration): Any person subject to Section 11-8-310 (hard chrome platter or anodizer) shall demonstrate compliance with the performance standard specified in Section 11-8-310 by a District approved source test. The source test is due within 60 days of the startup of the facility.
3. Hard Chrome Platters or Anodizers-Emission Standards
a. Section 11-8-310.1: Plating facilities that emit less than 2 lbs of hexavalent chromium per year must comply with Section 11-8-310.1 by achieving an emission factor of 0.15 mg/amp-hr or less. This is TBACT for plating facilities that emit less than 2 lbs/yr.
b. Section 11-8-310.2: Plating facilities that emit more than 2 lbs per year but less than 10 lb per year must comply with Reg 11-8-310.2 by achieving an emission factor of 0.03 mg/amp-hr of less. This is TBACT for plating facilities with hex chrome emissions in the 2 to 10 lb/yr category.
c. Section 11-8-310.3: Plating facilities that emit 10 or more pounds of hex chrome per year must comply with the most stringent level of control as outlined in Section 11-8-310.3. This level of control requires a maximum emission factor of 0.006 mg/amp-hr. This is TBACT for plating facilities in the 10 or greater lb/yr category.
B. Toxics
Sources must comply with the District's Risk Management Procedure. This procedure is briefly discussed as follows:
The air toxics policy is applicable to any source that emits any identified toxic chemical listed in the Air Toxic Screening Policy. Any source that emits a toxic chemical below its trigger level, or with a risk of 1 X 10-6 or less is considered a nonsignificant risk. If the TBACT level of control is employed, a risk of 10 X 10-6 or less is considered acceptable. Risk screens are conducted by the Toxics Section after the Permit Engineer provides the needed information to the Risk Screen Evaluator. The information required for the screen is listed on the Request for Information; Risk Screening Analysis form (attached).
7. EMISSIONS
A. Emission Factors
In general, the following uncontrolled factors are applicable:
1. Hard Chrome Plating or Anodizing: 5.3 mg/amp-hr
2. Decorative Chrome Plating: 0.5 mg/amp-hr
Contact the Air Toxics Evaluation Section for the latest uncontrolled and controlled emission factors for chrome plating operations.
B. Sample Emission Calculations
1. Decorative Chrome Plating Operation:
Throughput Basis: 2.5 E+06 amp-hr per year
Hex Chrome Emissions = (2.5 E+06 Amp-hrs/yr)(0.5 mg/amp-hr)(0.05)(1.0 E-03 g/mg)(2.203 E-03 lb/g) = 0.14 lb/yr
2. Hard Chrome Plating Operation:
Throughput Basis: 10 E+06 amp-hr per year
(Plant is subject to 0.03 mg/amp-hr control level)
Hex Chrome Emissions = (10 E+06 Amp-hrs/yr)(0.03 mg/amp-hr)(1.0 E-03 g/mg)(2.203 E-03 lb/g) = 0.661 lb/yr
8. CONDITIONS
Operating conditions control material usage and/or emissions in order to ensure compliance with District regulations and to maintain air emissions at permitted levels. The following samples show permit conditions for various chrome plating operations.
A. Sample 1: Decorative Chrome Plating Operation
1. Throughput
The total (net) throughput at chrome plating bath emission source shall not exceed (X) amp-hrs in any consecutive twelve month period.
2. Abatement
This source shall not be operated unless Fumetrol 101 Mist Suppressant (or equivalent) is used as directed by the manufacturer's instructions. This chrome plating facility shall maintain records of fume suppressant usage in this source.
3. Record Keeping
This facility shall keep monthly records (onsite) of current applied to this chrome plating source, integrated over time, in units of amp-hours. Such records shall be submitted to the BAAQMD on an annual basis (via the annual update procedure). These records shall be maintained for at least one year.
B. Sample 2: Hard Chrome Plating Operation
1. Throughput
The total annual (net) throughput at this source shall not exceed (X) MM Amp-hr in any consecutive twelve month period.
2. Abatement
This source shall not be operated unless a layer of mist suppressant foam (or equivalent) is maintained in the bath in accordance with manufacturer's instructions, and emissions are vented through (A-X, additional abatement equipment).
3. Source Test
Within 60 days of the start-up of this source a District-approved source test shall be performed and results submitted to determine the hexavalent chrome emission factor as required by BAAQMD Regulation 11 Rule 8. The results of this source test shall be used to demonstrate compliance with Condition 4, below, and Reg 11 Rule 8.
4. Emission Limits
The hexavalent chrome emission factor developed from the above source test shall not exceed X mg/amp-hr (see applicable standard, Reg 11-8-310).
5. Record Keeping
To comply with the above conditions, monthly records of current applied to this source integrated over time, in units of amp-hours, shall be kept (onsite) and maintained. Such records shall be submitted to the BAAQMD on an annual basis via the annual update program. These records shall be maintained at the plant site for at least one year.
9. ENFORCEMENT
Permit conditions are enforced by the inspection staff of the enforcement division during the start-up inspection, on-going inspections, and through record keeping by the applicant. The inspector compares the actual operation of the source to the conditions required in the permit, and to applicable regulations.
10. FEES
Per Regulation 3, the following fees are required for each source. Please note that fees are subject to change. The fees are to serve as examples only.
A. Filing Fee: $167
B. Schedule F:
1. Initial Fee: $117
2. Permit to Operate Fee: $84
3. Toxic Surcharge: Amount = the Initial Fee + 10% of Permit to Operate Fee
(For sources which will emit a compound declared as a toxic air contaminant by the Air Resources Board, applicants may also be required to pay the Toxic Air Contaminant Surcharge. Hexavalent chromium is subject to the toxic surcharge.)
4. Late Fee: Equal to initial fee
5. Retroactive Permit Fee: $84/yr
11. TOXICS
Air Toxic Screening Policy: This policy is applicable to any source that uses any identified toxic chemical listed in the policy. Any toxics source that uses a toxic chemical, listed in the Air Toxics Screening Policy, below its trigger level, or with a risk of less than or equal to 1 X 106, or if TBACT is used, is considered a nonsignificant risk and, if it also complies with all other applicable District rules and regulations, receives approval for a District Authority to Construct and Permit to Operate. Risk screens are conducted by the Toxics Section after the District Air Quality Engineer provides the needed information to the Toxics Section evaluator. This information consists of the type of toxic compounds to be emitted, the emission rate of the compound, stack characteristics (if applicable), and the proximity of other buildings and structures.