Subject: Chrome Plating
From: "Saved by Windows Internet Explorer 7"
Date: Sun, 20 Apr 2008 14:39:49 -0700

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outdated).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.