From: "Saved by Windows Internet Explorer 7" Subject: Chrome Plating Date: Sun, 20 Apr 2008 14:39:49 -0700 MIME-Version: 1.0 Content-Type: text/html; charset="iso-8859-1" Content-Transfer-Encoding: quoted-printable Content-Location: http://www.baaqmd.gov/pmt/handbook/chrome.htm X-MimeOLE: Produced By Microsoft MimeOLE V6.0.6000.16545 Chrome Plating

CHROME PLATING=20 (HEXAVALENT)

Last adopted: July 17, = 1991

Original Chapter = adopted in 1991=20 (some of the information contained in this chapter may be=20 outdated).

1. DESCRIPTION

This chapter covers the permitting of = hexavalent=20 chrome plating operations. These operations fall into three general = categories:=20 decorative chrome plating, hard chrome plating, and hard chrome = anodizing. All=20 of these processes emit hexavalent chromium in particulate (mist) form.=20 Hexavalent chrome has been identified as a toxic air contaminant (human=20 carcinogen) with no identifiable threshold for health effects. Any = facility=20 emitting hexavalent chrome must undergo the Authority to = construct/Permit to=20 Operate process as well as the District's air toxics health risk = screening (or=20 risk assessment) procedure.

In emissions potential, the order is 1) = hard chrome=20 plating, 2) hard chrome anodizing, 3) decorative chrome plating. Each of = these=20 will be outlined in turn.

2. APPLICATION CONTENTS

A. Data Forms

The following forms must be completed by = the person=20 submitting an applications (these forms are used by the District to = characterize=20 the type of process, size, flow rates, abatement devices, and exhaust = stacks of=20 the system):

Form P101-B: Application for Authority to = Construct=20 and Permit to Operate Industrial Sources

Form P-105: Small Business Certification = (if=20 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,=20 manufacturers literature.

Emission source test results from a = chrome plating or=20 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=20 material.

Information on whether the plant is = located within=20 1,000 feet of the outer boundary of a school.

Risk Assessment Analysis: Request for = information=20 form if a preliminary toxic risk screen is required.

Stack parameters (height, flow rate) for = vented=20 machines (needed for toxic evaluation)

Maximum feasible throughput: Maximum = annual=20 throughout in amp-hrs which the facility is willing to live with as an=20 enforceable permit condition. This limit determines which control = category the=20 facility must comply with.

3. COMPLETENESS

The following information is needed to = make this=20 determination:

A. All Authority to Construct = and/or Permit to=20 Operate fees must be paid.

B. All data forms listed in = Section 2A must be=20 completed by the applicant. In addition, the other information requested = in=20 Section 2B must be submitted when applicable.

C. Any additional information = needed to=20 calculate emissions.

D. Any additional information = needed to=20 complete a toxics risk assessment, if applicable.

4. REGULATIONS

A. Hexavalent chrome plating = operations are=20 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=20 applicable to any source that emits any identified toxic chemical listed = in the=20 Air Toxic Screening Policy. Any source that emits a toxic chemical below = its=20 trigger level, or with a risk of 1 X 10-6 or less is considered a = nonsignificant=20 risk. If the TBACT level of control is employed, a risk of 10 X 10-6 or = less is=20 considered acceptable. Risk screens are conducted by the Toxics Section = after=20 the Permit Engineer provides the needed information to the Risk Screen=20 Evaluator. The information required for the screen is listed on the = Request for=20 Information; Risk Screening Analysis form (attached). For TBACT = explanation see=20 Sections 5 and 6, following.

C. Public Notification within 1000 = ft of=20 school: Reg 2 Rule 1 Section 412 requires the APCO to prepare and = distribute a=20 public notice to the parents of children in any school within 1000 ft = from the=20 outer property lin of the proposed new or modified source. This form = shall be=20 distributed at least 30 days prior to the date final action on the = application=20 is to be taken by the APCO.

5. ABATEMENT EQUIPMENT

A. Decorative Chrome Plating: = Acceptable=20 control equipment for control of emissions from decorative plating = facilities=20 include the following methods: Note: each of the following methods = constitute=20 TBACT for the control of emissions from decorative chrome plating=20 facilities.

1. Mist suppressant foam maintained in = the tank in a=20 manner which has been demonstrated to the satisfaction of the APCO to = reduce=20 emissions of hexavalent chromium by 95 percent or more relative to = emissions=20 when a mist suppressant is not used.

2. A layer of plastic balls continuously = maintained=20 in the tank is a manner which has been demonstrated to the satisfaction = of the=20 APCO to reduce emissions of hexavalent chromium by 95 percent or more = relative=20 to emissions when plastic balls are not used.

3. Any equivalent method that is = demonstrated to the=20 satisfaction of the APCO to reduce emissions of hexavalent chromium by = 95=20 percent or more relative to emissions without control.

B. Hard Chrome Plating or = Anodizing:=20 Acceptable methods for the control of emissions of hexavalent chromium = form hard=20 chrome plating or anodizing operations include any process, procedure, = method or=20 appurtenance that can be demonstrated by District approved source test = to meet=20 the hexavalent chrome emission standard specified in Section = 6.

6. STANDARDS

A. Standards that must be met before a = permit can=20 be issued:

Regulation 11 Rule 8: Hazardous = Pollutants --=20 Hexavalent Chromium

1. General Requirements-All Chrome=20 Platters

a. Section 11-8-501 (Usage Records): All = chrome=20 plating or anodizing facilities must keep monthly records of current = applied to=20 the bath integrated over time.

b. Section 11-8-503 (Reporting): All = chrome plating=20 or anodizing facilities must submit records of current consumption to = the=20 District on an annual basis.

2. General Requirements-All Hard Chrome = Platters or=20 Anodizers

a. Section 11-8-330 (Stack = height/velocity): A person=20 shall not operate a source subject to Section 11-8-310 (hard chrome = platter or=20 anodizer) unless all exhausted emissions are emitted through a stack no = less=20 than 10 meters above grade at a velocity of no less than 10=20 meters/second.

b. Section 11-8-403 (Compliance = demonstration): Any=20 person subject to Section 11-8-310 (hard chrome platter or anodizer) = shall=20 demonstrate compliance with the performance standard specified in = Section=20 11-8-310 by a District approved source test. The source test is due = within 60=20 days of the startup of the facility.

3. Hard Chrome Platters or = Anodizers-Emission=20 Standards

a. Section 11-8-310.1: Plating facilities = that emit=20 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=20 TBACT for plating facilities that emit less than 2 lbs/yr.

b. Section 11-8-310.2: Plating facilities = that emit=20 more than 2 lbs per year but less than 10 lb per year must comply with = Reg=20 11-8-310.2 by achieving an emission factor of 0.03 mg/amp-hr of less. = This is=20 TBACT for plating facilities with hex chrome emissions in the 2 to 10 = lb/yr=20 category.

c. Section 11-8-310.3: Plating facilities = that emit=20 10 or more pounds of hex chrome per year must comply with the most = stringent=20 level of control as outlined in Section 11-8-310.3. This level of = control=20 requires a maximum emission factor of 0.006 mg/amp-hr. This is TBACT for = plating=20 facilities in the 10 or greater lb/yr category.

B. Toxics

Sources must comply with the District's = Risk=20 Management Procedure. This procedure is briefly discussed as = follows:

The air toxics policy is applicable to = any source=20 that emits any identified toxic chemical listed in the Air Toxic = Screening=20 Policy. Any source that emits a toxic chemical below its trigger level, = or with=20 a risk of 1 X 10-6 or less is considered a nonsignificant risk. If the = TBACT=20 level of control is employed, a risk of 10 X 10-6 or less is considered=20 acceptable. Risk screens are conducted by the Toxics Section after the = Permit=20 Engineer provides the needed information to the Risk Screen Evaluator. = The=20 information required for the screen is listed on the Request for = Information;=20 Risk Screening Analysis form (attached).

7. EMISSIONS

A. Emission Factors

In general, the following uncontrolled = factors are=20 applicable:

1. Hard Chrome Plating or Anodizing: 5.3=20 mg/amp-hr

2. Decorative Chrome Plating: 0.5=20 mg/amp-hr

Contact the Air Toxics Evaluation Section = for the=20 latest uncontrolled and controlled emission factors for chrome plating=20 operations.

B. Sample Emission = Calculations

1. Decorative Chrome Plating = Operation:

Throughput Basis: 2.5 E+06 amp-hr per = year

Hex Chrome Emissions =3D (2.5 E+06 = Amp-hrs/yr)(0.5=20 mg/amp-hr)(0.05)(1.0 E-03 g/mg)(2.203 E-03 lb/g) =3D 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=20 level)

Hex Chrome Emissions =3D (10 E+06 = Amp-hrs/yr)(0.03=20 mg/amp-hr)(1.0 E-03 g/mg)(2.203 E-03 lb/g) =3D 0.661 lb/yr

8. CONDITIONS

Operating conditions control material = usage and/or=20 emissions in order to ensure compliance with District regulations and to = maintain air emissions at permitted levels. The following samples show = permit=20 conditions for various chrome plating operations.

A. Sample 1: Decorative Chrome = Plating=20 Operation

1. Throughput

The total (net) throughput at chrome = plating bath=20 emission source shall not exceed (X) amp-hrs in any consecutive twelve = month=20 period.

2. Abatement

This source shall not be operated unless = Fumetrol 101=20 Mist Suppressant (or equivalent) is used as directed by the = manufacturer's=20 instructions. This chrome plating facility shall maintain records of = fume=20 suppressant usage in this source.

3. Record Keeping

This facility shall keep monthly records = (onsite) of=20 current applied to this chrome plating source, integrated over time, in = units of=20 amp-hours. Such records shall be submitted to the BAAQMD on an annual = basis (via=20 the annual update procedure). These records shall be maintained for at = least one=20 year.

B. Sample 2: Hard Chrome = Plating=20 Operation

1. Throughput

The total annual (net) throughput at this = source=20 shall not exceed (X) MM Amp-hr in any consecutive twelve month period.=20

2. Abatement

This source shall not be operated unless = a layer of=20 mist suppressant foam (or equivalent) is maintained in the bath in = accordance=20 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=20 District-approved source test shall be performed and results submitted = to=20 determine the hexavalent chrome emission factor as required by BAAQMD = Regulation=20 11 Rule 8. The results of this source test shall be used to demonstrate=20 compliance with Condition 4, below, and Reg 11 Rule 8.

4. Emission Limits

The hexavalent chrome emission factor = developed from=20 the above source test shall not exceed X mg/amp-hr (see applicable = standard, Reg=20 11-8-310).

5. Record Keeping

To comply with the above conditions, = monthly records=20 of current applied to this source integrated over time, in units of = amp-hours,=20 shall be kept (onsite) and maintained. Such records shall be submitted = to the=20 BAAQMD on an annual basis via the annual update program. These records = shall be=20 maintained at the plant site for at least one year.

9. ENFORCEMENT

Permit conditions are enforced by the = inspection=20 staff of the enforcement division during the start-up inspection, = on-going=20 inspections, and through record keeping by the applicant. The inspector = compares=20 the actual operation of the source to the conditions required in the = permit, and=20 to applicable regulations.

10. FEES

Per Regulation 3, the following fees are = required for=20 each source. Please note that fees are subject to change. The fees are = to serve=20 as examples only.

A. Filing Fee: = $167

B. Schedule F:

1. Initial Fee: $117

2. Permit to Operate Fee: $84

3. Toxic Surcharge: Amount =3D the = Initial Fee + 10% of=20 Permit to Operate Fee

(For sources which will emit a compound = declared as a=20 toxic air contaminant by the Air Resources Board, applicants may also be = required to pay the Toxic Air Contaminant Surcharge. Hexavalent chromium = is=20 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=20 to any source that uses any identified toxic chemical listed in the = policy. Any=20 toxics source that uses a toxic chemical, listed in the Air Toxics = Screening=20 Policy, below its trigger level, or with a risk of less than or equal to = 1 X=20 106, or if TBACT is used, is considered a nonsignificant risk and, if it = also=20 complies with all other applicable District rules and regulations, = receives=20 approval for a District Authority to Construct and Permit to Operate. = Risk=20 screens are conducted by the Toxics Section after the District Air = Quality=20 Engineer provides the needed information to the Toxics Section = evaluator. This=20 information consists of the type of toxic compounds to be emitted, the = emission=20 rate of the compound, stack characteristics (if applicable), and the = proximity=20 of other buildings and structures.