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U.S. EPA Publishes Final Chromium Air Standards TodayThe U.S. Environmental Protection Agency today published its
final rule to significantly tighten air emission standards for
chromium electroplating and anodizing operations. To download a
copy from the NASF website, click here.
The regulation, which was finalized to meet an August 15, 2012
court-ordered deadline, imposes new stringent air emission limits, lower
surface tension levels, new housekeeping practices, and a ban of
PFOS-based fume suppressants.
After three years of discussions and data review with NASF,
EPA issued the tougher standard under the federal NESHAP (National
Emission Standard for Hazardous Air Pollutants) program even though the
agency concluded that the industry's emissions have dramatically
improved since the original 1995 chromium air rule and do not pose a
health risk to the public.
NASF reminded EPA at a recent meeting with White House officials
that the agency provided no credible rationale for lowering existing
limits. NASF has prepared a brief summary of the rule below. The
final rule in published form is available here.
For more detailed information, please email Jeff Hannapel at The Policy Group or call (202) 257-3756. |
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February 24-28, 2013
Key West, FL
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April 9-11, 2013
Washington D.C.
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June 10-12, 2013
Rosemont, IL
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EPA Air Chromium Standards Summary
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EPA's New Chromium Air Emission Requirements
Lower Surface Tension Levels
The rule lowers the required surface tension levels from 35
dynes to 33 when measuring with a tensiometer and from 45 dynes to 40
when measuring with a stalagmometer. NASF does not view this change as a
significant revision to the current requirement.
Lower Emission Limits
The new rule has tightened emissions limits to the lowest
in the world for both existing and new decorative chromium plating,
chromic acid anodizing, and hard chromium plating process. EPA reduced
the emissions limits by a range of 25 to 50 percent for existing
sources, and all new sources must comply with a new limit of 0.006
mg/dscm, which is 40 to 60 percent lower than the previous limits.
Certain facilities are able to meet the new limits, while
others may face significant compliance costs.
Please see the table of changes below:
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New Limits |
Previous Limits | |
Decorative Chromium Plating | | | |
Existing Sources |
0.007 mg/dscm |
0.010 mg/dscm | |
New Sources |
0.006 mg/dscm |
0.010 mg/dscm | |
Chromic Acid Anodizing | | | |
Existing Sources |
0.007 mg/dscm |
0.010 mg/dscm | |
New Sources |
0.006 mg/dscm |
0.010 mg/dscm | |
Hard Chromium Plating | | | |
Existing Sources (small) |
0.015 mg/dscm |
0.030 mg/dscm | |
New Sources (small) |
0.006 mg/dscm |
0.015 mg/dscm | |
Existing Sources (large) |
0.011 mg/dscm |
0.015 mg/dscm | |
New Sources (large) |
0.006 mg/dscm |
0.015 mg/dscm |
Demonstrating Compliance with Emission Limits
Facilities must demonstrate
compliance with the new limits by conducting a performance or stack
test. Facilities may use a previous performance test to demonstrate
compliance with the new emission limits, provided that:
- the test was conducted after January 25, 1995
- the source is using the same emission controls that were used during the compliance test
- the
source was operating under conditions that are representative of the
conditions under which the source was operating during the compliance
test
- the test was based on approval from a permitting authority
California Housekeeping Practices
Companies
must implement the following housekeeping practices designed to
minimize chromium emissions, in line with California's current
requirements: - substances that include hexavalent chromium must be stored in closed containers
- take measures to minimize spills of bath solutions
- install splash guards for spraying operations
- cleanup or contain spills within one hour of the spill
- clean surface with HEPA vacuuming, hand-wiping, wet mopping, or hosing down and collecting in wastewater collection system
- separate buffing, grinding and polishing operations from electroplating and anodizing processes with a physical barrier
- take measures to minimize fugitive dust emissions
PFOS-based Fume Suppressants Ban The regulation bans the use of fume suppressants that contain one percent or greater of PFOS by weight.
Effective Dates
The
final regulation is effective upon today's publication in the Federal
Register. Facilities must comply with the following provisions of the
new standard by the following dates: housekeeping practices - within 60
days of the date of publication in the Federal Register; surface tension
levels - within 2 years of the date of publication in the Federal
Register; emission limits - within 2 years of the date of publication in
the Federal Register; ban of PFOS fume suppressants - within 3 years of
the date of publication in the Federal Register Process for Challenging the Final Rule The
NASF is reviewing the rule closely and is considering a legal challenge
to the agency's action in the final rulemaking package. Petitions for
judicial review of the final rule must be submitted to the U.S. Court of
Appeals within 60 days of the date of publication in the Federal
Register. This process can take up to a year or more to completeIn
addition, NASF may have an option to submit a petition for
reconsideration of the rule to EPA. Pursuing such an option may depend
on the Agency's willingness to entertain such a reconsideration of the
rule. NASF's Government Advisory
Committee is meeting this week to discuss the industry impacts of the
final rule. For any questions or additional information on the revised
standard, please contact Jeff Hannapel at jhannapel@thepolicygroup.com or 202-257-3756.
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This email was sent to you by the National Association for Surface
Finishing. To learn more about, support or join the National Association
for Surface Finishing, call 202-457-8404; email Phil Assante, Jeff Hannapel or Christian Richter; or visit NASF.org. © Copyright 2012. National Association for Surface Finishing. All rights reserved. |
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