New Chromium Electroplating Housekeeping Requirements

On September 19, EPA finalized the residual risk and technology review for the national emission standards for hazardous air pollutants (NESHAP) for hard and decorative chromium electroplating and chromium anodizing tanks under 40 CFR Part 63. While NASF and the Sierra Club are litigating the rule in federal appeals court in Washington, as part of the final rule, EPA incorporated several housekeeping practices into 40 CFR 63.342(f), based on the 2007 amendments to California’s ATCM for Chromium Plating and Chromic Acid Anodizing Facilities.

These measures are intended to reduce potential fugitive chromium emissions from chromium electroplating and anodizing operations.

Chrome plating facilities subject to the rule are required to implement new housekeeping practices no later than March 19, 2013. (The compliance deadline for revised emission limits and surface tension levels in the final rule is not until Sept. 19, 2014.) Not only must facilities implement these practices pursuant to the rule, facilities must also amend their Operation and Maintenance Plans to incorporate the housekeeping practices provisions.

The housekeeping practices are summarized below, and each is presented with more detail on PFOnline.com/blog.

1. Store substances that contain hexavalent chromium in closed containers.

2. Minimize spills of bath solutions, including installing drip trays.

3. Install splash guards for spraying (i.e., rinsing) operations.

4. Clean up or contain spills within one hour of the spill.

5. Clean surfaces with HEPA vacuuming, hand-wiping, wet mopping, or hosing down and collecting in wastewater collection system.

6. Separate buffing, grinding and polishing operations from electroplating and anodizing processes with a physical barrier.

7. Take measures to minimize fugitive dust emissions.

While the rule spells out the specific housekeeping practices that must be implemented, further clarification is needed to provide greater certainty for facilities and regulators on what activities would satisfy the regulatory requirements. NASF is working with EPA to develop a document that more clearly outlines what specific activities would be sufficient to satisfy these requirements.

If you would like additional information, contact Jeff Hannapel at jhannapel@thepolicygroup.com.

National Association for Surface Finishing