U.S. Environmental Protection Agency

COMMON SENSE INITIATIVE

Metal Finishing Subcommittee

CLEANER CHEAPER SMARTER

In Cooperation with

The National Institute of Standards Technology

Manufacturing Extension Partnership

HARD CHROME POLLUTION PREVENTION

DEMONSTRATION PROJECT REPORT

for

Plating Perceptions, Inc.

Prepared by CAMP, Inc.'s

Great Lakes Manufacturing Technology Center

January 20, 1998
Notice

The U.S. Environmental Protection Agency, through its Office of Research and Development,

partially funded, managed, and collaborated in the research described here under Assistance

Agreement Number DW-13936163 to the National Institute of Standards and Technology

Manufacturing Extension Partnership. This report has been subjected to the EPA's peer review

and administrative review and has been approved for publication as an EPA document.

The contents of this report are offered as guidance and source for opportunities. CAMP, Inc./

The Great Lakes Manufacturing Technology Center, the Industrial Technology Institute, Sandia

National Laboratories, the Northeast Midwest Institute, and all technical sources referenced in

this report do not: (a) make any warranty or representation, expressed or implied, with respect to

the accuracy, completeness, or usefulness of the information contained in this report, or that the

use of any information, apparatus, method, or process disclosed in this report may not infringe on

privately-held rights; (b) assume any liabilities with respect to the use of any information,

apparatus, method'or process disclosed in this report; (c) give any assurance regarding the

company's compliance with federal, state, or local regulations. This report does not reflect

official view or policy of the above-mentioned institutions. Mention of trade names or

commercial products does not constitute endorsement or recommendation of use.
Abstract

The EPA Common Sense Initiative (CSI) is cooperative effort between government

industry, environmental and other stakeholder groups to find "cleaner, cheaper smarter"

approaches to environmental management in industrial sectors. The CSI Metal Finishing

Subcommittee endorsed and provided technical oversight for the Hard Chrome Pollution

Prevention Demonstration Project. The purpose of this Project is to assist hard chrome metal

platers to cost-effectively comply with, or do better than, EPA's MACT Standard for Chromium Emissions.

In this Project, five chromium emission prevention/control devices were tested that cover

the spectrum of prevention/control techniques currently in use in hard chrome plating facilities

The Project found that dual- and tri-meshpad mist eliminators and chemical mist suppressants

were effective in Umiting chromium emissions to the levels, or better than the levels, specified in

the Standard, i.e., 0.030 milligrams per dry standard cubic meter of air (mg/dscm) for "small"

faculties with "existing" tanks, and 0.015 mg/dscm for "small" facilities with "new" tanks or 'large" facilities with "existing" or "new" tanks.

All activities related to the Project were developed byjhe Project participants with input

from the management of the participating electroplating companies, and reviewed by an EPAselected peer review panel of representatives from industry, equipment and chemical suppliers 9nn and academia. araHamto rtr

The following report details the portion of the Project that investigated the use of dual- meshpad mist eliminator and also tri-meshpad mist eliminator.

in
Acknowledgments

This Project originated as result of an inter-governmental agency agreement (Assistance

Agreement No. DW-13936163) between the Environmental Protection Agency's (EPA) Office

of Research and Development (ORD) and the National Institute of Standards and Technology

(NIST) Manufacturing Extension Partnership (MEP) to conduct demonstration project of

pollution prevention technologies that would assist typical metal finishers to achieve improved

environmental and economic results.

These two groups then joined with the EPA Office of Pollution Prevention and Toxics

(OPPT) design for the Environment (DfE) Program, the Department of Energy (DoE) Office of

Industrial Technologies (OIT), industry (National Association of Metal Finishers, American

Electroplaters and Surface Finishers), and other parties in Technology Reinvestment Project

(TRP) called the Energy, Environment, and Manufacturing (EEM) Project. The EEM Project is

one of the most significant collaborations of these three Federal agencies with the private sector

for energy, environmental and economic benefits.

When the EPA's Common Sense Initiative was created, it seemed natural that the Metal

Finishing Subcommittee would endorse this project as one that the Subcommittee's Research and

Technology Work Group would oversee. The result of the Work Group's and the

Subcommittee's deliberations was that the demonstration portion of the EEM Project would

focus on evaluating the effectiveness and cost of pollution prevention techniques in helping

typical hard chrome metal finishers comply with, or do better than, the EPA-promulgated MACT

Standard. In addition, endorsement of the Project by the CSI Metal Finishing Subcommittee

resulted in extensive peer review by industry, environmental, and academic experts.

The Hard Chrome Pollution Prevention Demo Project was managed by two centers,

specifically by Dr. Kenneth Saulter at the Industrial Technology Institute (ITI) in Ann Arbor,

Michigan, and Larry Boyd and Dr. Gus Eskamani at CAMP, Inc.'s Great Lakes Manufacturing

Technology Center (GLMTC) in Cleveland, Ohio. The Project Team included James Hensley

and Christine Branson at ITI and Lisa D' Agostino at CAMP/GLMTC. Brian Sweeney of NISTMEP provided crucial oversight of the Project and served as the liaison between the Project

managers, i.e., NIST and EPA. Joe Breen of OPPT/DfE made available critical analytical

capabilities.

The CSI Metal Finishing Subcommittee Research and Technology Work Group is cochaired by Brian Manty of Concurrent Technologies Corporation and Tim Oppelt, Director of the

ORD National Risk Management Research Laboratory (NRMRL). Dave Ferguson of the ORDNRMRL is the EPA Project Officer for the Project. Paul Shapiro, ORD-CSI Coordinator and

Co-Lead of the Metal Finishing Sector, provided guidance for the overall Project.

The work described in this report was performed by the CAMP/GLMTC, in collaboration

with ITI, Sandia National Laboratories, and the Northeast Midwest Institute.

IV
Table of Contents

Abstract

Acknowledgments

Tables

I.

n.

m.

IV.

v.

VI.

vn.

vm.

Introduction

A. Project Goal

B. Project Objectives

C. Project Background

Project Executive Summary

Site Selection

Site Description

A. Dry, Dual-Meshpad Mist Eliminator

B. Wet, Tri-Meshpad Mist Eliminator

Anticipated Company/Industry Benefits

Work Plan and Deliverables

Data Collection and Analysis Plan

Results and Discussion of Results

A.

B.

C.

D.

E.

F.

G.

Outlet Hexavalent Chromium Emissions

Comparison of Method 306 and Method 306A

Prevention/Control Device Efficiency

Above-Tank Total Chromium Air Concentrations

Prevention/Control Device Inlet Hexavalent Chromium Concentrations

Freeboard

Ventilation Rates

DC. PPI's Pollution Prevention Features

X. Conclusions

XI. Post-Project Summary

XII. Responsibilities and Funding

REFERENCES

Appendix A: SUMMARY OF BASELINE METHOD 306 CHROME DEMO TESTS

Appendix B: SUMMARY OF BASELINE METHOD 306A CHROME DEMO TESTS

Appendix C: ADDITIONAL BASELINE TEST RESULTS

Appendix D: GLOSSARY OF TERMS

Appendix E: ABBREVIATIONS USED IN THIS DOCUMENT

Appendix F: CONTACT INFORMATION

Page

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iv

vi

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15

16

17

18

19

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23

25
Tables

Table 1. USEPA Chromium Emissions MACT Standard Limits

Table 2. Prevention/Control Devices Used to Determine the Standard

Table 3. Baseline Test Plan

Table 4. Modified Method 306 Test Results, Hexavalent Chromium

Table 5. Test Results for Outlet Hexavalent Chromium Emissions

Table 6. Method 306 Method 306A Comparison, Hexavalent Chromium

Table 6A. Method 306 Modified Method 306A Comparison, Hex. Chromium

Table 7: Device Percent Efficiency and mg/Amp-hr for Hexavalent Chromium

Table 8: Above-Tank Total Chromium Air Concentrations

Table 9: Inlet Hexavalent Chromium Concentrations

Table 10: Freeboard

Table 11: OSHA Minimum Ventilation and Test Ventilation Rates

Page

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VI
I. Introduction

As part of new proactive approach to environmental compliance, the USEPA is working

with six industrial sectors in nationwide effort to encourage voluntary and cooperative efforts

that involve industry, government, and public interest groups. Called the "Common Sense

Initiative" (CSI), the program seeks out "Cheaper, Cleaner, Smarter" approaches to

environmental management. CSI has encouraged and supported variety of projects, including

technology demonstration projects within the metal finishing industry.

The purpose of this CSI Chrome Demonstration Project is to help small to medium-sized

hard chrome plating shops to cost-effectively comply with, or do better than, the USEPA's

Maximum Achievable Control Technology (MACT) Standard for Chromium (regulatory

reference 40CFR Parts and 63: National Emission Standards for Chromium Emissions From

Hard and Decorative Electroplating and Chromium Anodizing Tanks). The Project was able to

benefit from related work underway by the Energy, Environment, and Manufacturing (EEM)

Technology Access Project of the Technology Reinvestment Program (TRP), partnership of several federal agencies.

Funding for the TRP Grant was provided by the Department of Commerce's National

Institute of Standards and Technology (NIST) Manufacturing Extension Program (MEP); the

United States Environmental Protection Agency's (USEPA) Design for the Environment Group;

the USEPA's Office of Research and Development; and the Department of Energy's (DoE)

Office of Industrial Technologies.

The Department of Commerce's National Institute of Standards Technology (NIST)

Manufacturing Extension Partnership (MEP) has been working with the USEPA to bring

environmental technical assistance services to small and medium-sized manufacturers.

The USEPA's Design for the Environment (DfE) Program uses the USEPA's expertise

and leadership to exchange information and research on risk reduction and pollution prevention

efforts. USEPA-DfE is one of the funders in the EEM-TRP, where the focus in on helping

manufacturers make more informed choices regarding pollution prevention and waste reduction opportunities.

The USEPA's Office of Research Development (ORD) is the scientific and technical

arm of the USEPA. ORD focuses on the advancement of basic, peer-reviewed scientific research

and on the implementation of cost-effective, common sense technology.

The Department of Energy's (DoE) Office of Industrial Technologies (OIT) has

sponsored program on assessments which identify energy-efficient measures that will result in

pollution prevention and "green" plant/process design.

The Research and Technology Workgroup, Workgroup of the USEPA-CSI Metal

Finishing Subcommittee, is the lead oversight group in the NIST-MEP/USEPA-CSI technology

demonstration projects. The objective of these projects are to demonstrate low-cost

1/20/98
improvements which emphasize pollution prevention in meeting the Chromium MACT

Standard. The USEPA will use information from these projects as case studies which provide

more formal guidance on low-cost upgrades to meet the Chromium MACT Standard.

CAMP, Inc's Great Lakes Manufacturing Technology Center (GLMTC) acted as the

Project Manager for two of the four CSI-Chromium Demonstration Projects. CAMP/GLMTC is

not-for-profit technical service provider in Northeast Ohio, specializing in improving the

performance and competitiveness of small to medium-sized manufacturers.

A. Project Goal

The major goal for this Project is to provide information to hard chromium metal platers,

particularly small and medium-sized job shops, that will assist them in cost-effectively meeting,

or doing better than, the chromium air emissions limits. These limits must be met by all hard

chromium electroplating shops under the USEPA's Office of Air Quality Planning and

Standards-promulgated 1995 National Emission Standards for Chromium Emissions from Hard

and Decorative Chromium Electroplating and Chromium Anodizing Tanks (Chromium

Emissions MACT Standard).

B. Project Objectives

Overall Project Objectives are to:

1. Demonstrate real-world baseline of typical electroplating source emission

prevention and control techniques;

2. Determine if the EPA-mandated emission limits can be met under job-shop working

conditions;

3. Determine low or lower-cost emission prevention and control techniques that

emphasize pollution prevention;

4. Demonstrate methods of reducing trivalent, hexavalent, and total chromium emissions

into the environment.

Specific Demonstration Project Objectives are to:

1. Identify and test potential retrofits of in-place technology to meet the Chromium

MACT Standard (hereinafter, the Standard).

2. Identify and test combinations of bath additives and/or process control that can meet

the Standard.

C. Project Background

Hard chrome platers must report their source outlet chromium emissions on either total

chromium (i.e., trivalent plus hexavalent) or hexavalent chromium basis. The facility has the

option of selecting which form of chromium to report.

The Standard includes two designations for hard chromium electroplating facilities, based

upon the maximum cumulative potential rectifier capacity and when the source(s) (e.g.,

electroplating tank(s)) were installed. facility is designated as "large" if the rectifier capacity

for all hard chromium electroplating tanks equals or exceeds 60 million ampere-hours per year.

"small" facility is one at which the rectifier capacity is less than 60 million ampere-hours per

1/20/98
year. In addition, an electroplating tank is "new" if it was installed or reconstructed after

December 16, 1993. tank is "existing" if it was installed on to prior to that date. Table lists

the chromium emissions limits as required by the Standard.

Table 1: USEPA Chromium Emissions MACT Standard Limits

Tank Status "Small" Facility ''Large" Facility

all "existing" tanks 0.03 milligram/dry standard cubic

meter

0.015 milligram/dry standard cubic

meter

all "new" tanks 0.015 milligram/dry standard cubic

meter

0.015 milligram/dry standard cubic

meter

The Standard is based upon the use of prevention/control devices listed in Table 2:

Table 2: Prevention/Control Devices Used to Determine the Standard

Facility Classification Prevention/Control Device Used

'small" facility packed-bed scrubber with water addition to top of scrubber

large" facility multi-stage composite meshpad-style mist eliminator

The Chromium Demonstration Project investigated pollution prevention methods and

control techniques that EPA "small" and "large" facilities can implement to meet the Chromium

MACT Standard. Both mechanical (that is, the physical separation of chromium mist from air)

and chemical techniques (for example, chemical mist suppressants) were investigated.

The Project was divided into four phases:

Phase Selecting representative prevention/control devices of hard chromium

emission sources from variety of "small" and "large" facilities.

Phase Baseline testing of the prevention/control devices to provide data for:

a) comparison with post-modification testing results and

b) selection of devices which need to be modified to meet the Chromium MACT

Standard.

Phase Selecting and installing low-cost emission reduction techniques to the

sources that did not meet the Standard.

Phase Testing and evaluating the newly-installed techniques.

An EPA-selected Peer Review Expert Panel reviewed and commented on Project

activities. The results of the reviews were presented for approval to the Research and

Technology Work Group of the CSI Metal Finishing Subcommittee. Only after Work Group

approval were the proposed activities undertaken. The Peer Review process covered such

activities as:

selection of the prevention/control devices to test

development of the sampling protocols

selection of the stack testing firm to use for Phases and

selection of the analytical laboratories to use for Phases and

selection of the prevention/control techniques to install.

This report was peer-reviewed prior to release.

1/20/98
n. Executive Summary

Plating Perceptions, Inc. (hereinafter PPI), metal finisher specializing in hard chrome

plating, serves many industries, including the automotive, defense and aerospace industries.

Chosen as Project participant, PPI received number of tests on their two hard chrome sources

(i.e., plating baths) in October, 1995. (Note: total of five sources, three in Ohio and two in

Michigan, were studied in this CSI-Demonstration Project.) This testing included pre- and postprevention/control equipment emissions testing and above-tank emissions testing. Based upon

the results of this testing, PPI was able to determine their compliance status relative to the

Standard. In addition, with PPI input, site-specific Operation and Maintenance Manual was

developed and implemented at PPI. The other beneficiary, the metal finishing industry, received

valuable information concerning specific prevention/control equipment relative to compliance

with the Standard.

III. Site Selection

CAMP, Inc. and ITI began their search for potential Ohio and Michigan demonstration

sites in April, 1995. Potential Ohio hard-chrome plating sites were supplied by Industry Council

representatives. local Ohio metal finisherjhen assisted Ohio site selection by contacting his

colleagues to determine their interest in participating in this project. All interested Ohio sites

(five in number) were contacted and visited in June, 1995, by CAMP/GLMTC, ITI and two

Industrial Council representatives/consultants. Each site was then evaluated as to their processes,

prevention/control equipment, and potentialJor demonstration technologies.

USEPA-selected Peer Review Panel chose the three best Ohio sites from the list of

five. Midwest Research Institute, the chosen Project testing and analytical laboratory, visited all

three sites in August, 1995 to evaluate testing feasibility and determine testing costs.

In September 1995, two sites (i.e., PPI and another) were asked to participate after

further review of the facilities by the Peer Review Panel. The shops were selected as they had

industry-representative emission prevention/control devices covering variety of types. Not all

emission sources at each facility were selected. In other words, only those sources connected to

the control devices of interest were chosen.

Specifically, PPI was selected as demonstration site for several reasons, among them:

documentation of their current pollution prevention activities would benefit the metal

plating industry

their involvement in the testing which led to EPA Method 306A supplied baseline

to which current testing could be compared.

they operated wet tri-meshpad mist eliminator and dry, dual-meshpad mist

eliminator

1/20/98
IV. Site Description

Starting in 1988 with just four walls, the ceiling and concrete floor, Randy Taylor and

his partner Randy Bauer built their successful business. Anticipating that environmental, health

and safety regulations would be increasing, they installed the most advanced technology and

features which were available. These technologies/features include:

wet or dry, multi-stage meshpad mist eliminators

recycling and reclaiming of all process solutions through spray rinsing and countercurrent rinsing

secondary containment around all tanks

Located in Twinsburg, Ohio, the facility occupies approximately 10,000 square feet and

employs about 12 employees. They operate two hard chrome plating baths; one with dry, dual

meshpad mist eliminator; and the other with wet, tri-meshpad mist eliminator. Both control

devices, manufactured by ChromeTech, Inc., of Windsor, Ohio, have the exhaust fan located

after the control units. Both have an exhaust hood which is a push-pull single-sided lateral-style

hood that has single take-off and single three-inch tall slot down the long side of the tank. All

parts are spray-rinsed, and all rinse tanks are piped to make use of the countercurrent-rinsing

technique. The entire plating process is close-looped, i.e., there are no liquid wastes_generated or

discharged.

PPI is calculated "small" facility per the Standard definition (i.e., their maximum

potential rectifier capacity is less than 60 million ampere-hours per year). As such, the

chromium emission limit for each of the two test sources is 0.03 mg/dscm.

A. Dry, Dual Meshpad Mist Eliminator

One PPI prevention/control device is 117 dscm/min. air flow horizontal, dry, twomeshpad mist eliminator. At baseline testing, this unit was approximately years old and the

meshpad was approximately one year old. The device, duct work and fan are of plastic

construction. The meshpads are washed in place daily and are removed and cleaned weekly.

Project participants did not expect this device to meet the Standard emission limit for an EPA

"large" facility. This device is connected to single 20 square foot 1,735 gallon tank. single

rectifier is used at the tank. Normal amperage used is in the 3000 3500 Amp range with

maximum amperage of 6000 Amp. The average plating batch time is four hours.

The push-pull exhaust system used consists of low-profile hood opposite push air

header. The exhaust hood is "C"-shaped so that exhaust air is removed from the side opposite

the air header and the ends of the tank. fan is located after the control device so that it is

exposed to only "clean" air. Its vertical stack was used for outlet testing.

According to vendors, new meshpad mist eliminator costs approximately $35,000

$45,000. Estimated annual operating costs are about $15,000.

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B. Wet, Tri-Meshpad Mist Eliminator

The other PPI prevention/control device is an 88 dscm/min. air flow, horizontal, wet,

three-meshpad mist eliminator. At baseline testing, it was approximately years old and the

meshpad was approximately one year old. Project participants expected this device to meet the

MACT Standard limit for an EPA "small" facility. However, it was included in this study in

order to determine if it could meet the limit for an EPA "large" facility. In addition, this device

had been tested four years previously during the EPA's development testing for the Method

3O6A procedure. Project participants wanted to determine if there was any degradation of the

device over time (four years, in this case). This device is connected to single 20 square foot

1,735 gallon tank. single rectifier is used at the tank. Normal amperage used is in the 2500

3000 Amp range with maximum amperage of 4000 Amp. The average plating batch time is

four hours.

The push-pull exhaust system used consists of low-profile hood opposite push air

header. The exhaust hood is "C"-shaped so that exhaust air is removed from the side opposite

the tdr header and the ends of the tank. fan is located after the control device so that it is

exposed to only "clean" air. The vertical stack was used for outlet testing.

To assist in the chromium mist entrainment process, deionized water is recirculated and

"sprayed onto the front of the second meshpad. The meshpads are continuously washed in front

of the first two meshpads while in place. Deionized water is recirculated to the pads from tank

under the device. The air flow is horizontal. The meshpads are also removed and cleaned

weekly.

According to vendors, a new meshpad mist eliminator costs approximately $35,000

$45,000. Estimated annual operating costs are about $15,000.

V. Anticipated Company/Industry Benefits

PPI anticipated that participation in this Project would enable them to document their

compliance status. Project co-participants anticipated that this Project would benefit the Metal

Finishing Industry, and in particular, the Hard Chrome Plating Industry, in the following ways:

determination of the control efficiency of dry, dual-meshpad mist eliminator

determination of the control efficiency of wet, tri-meshpad mist eliminator

documentation of effective pollution prevention methods, such as spray rinsing,

countercurrent rinsing, and close-looping of process liquids

documentation of effective environmental management activities, such as secondary

containment for all process tanks.

VI. Work Plan and Deliverables

AH proposed Project activities were developed by CAMP and ITI, then presented to an

EPA-selected Peer Review Expert Panel. The results of the Peer Panel review were presented for

review and approval to the Research and Technology Work Group of the CSI Metal Finishing

Subcommittee. Upon Work Group approval, the proposed activities were implemented.

1/20/98
There were four phases to this project:

1. Conduct baseline testing to determine current chromium emissions, i.e., pre-control

unit emissions, stack emissions, and above-tank emissions.

2. Recommend and implement modifications and upgrades as necessary. If stack

emission results indicate non-compliance with the Chromium MACT Standard,

identify, select, and implement/install modifications/upgrades as necessary. If stack

emission results indicate compliance, document situation and prepare Operations

Maintenance Manual.

3. If upgraded, collect post-modification and upgrade data to determine their impact on

chrome emissions.

4. Draft Demonstration Project Technical Reports that report and assess the baseline

data collection results, the modifications and upgrades recommended and

implemented (if applicable), and the post-modification and upgrade chrome emission

results and analysis (if applicable).

PPI's deliverables were to be as follows:

1. Baseline Testing results, including pre-control unit emissions, stack emissions, and

above-tank emissions.

2. Low-cost modification(s), as necessary.

3. Post-modification results, including pre-control unit emissions, stack emissions, and

fugitive emissions (if applicable).

4. PPI Operations and Maintenance Manual.

5. Final PPI CSI-Demonstration Project Report.

VII. Data Collection and Analysis Plan

Beginning in July, 1995, the Baseline Test Plan (Table 3) was developed by the Project

participants, the CSI-Metal Finishing Research and Technology Workgroup, and later reviewed

and approved by consultants and the EPA-selected Peer Review Panel.

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Table 3: Baseline Test Plan

Inlet:

EPA Method 306 for Total Chromium and Hexavalent Chromium

Air Flow

Outlet:

EPA Method 306 for Total Chromium and Hexavalent Chromium

EPA Method 306A for the wet, tri-meshpad control device

Air Flow

Device:

Pressure Drop across Unit

Bath:

Above-Tank Chromium Air Emissions

Amp-Hr

Specific Gravity

Temperature

Freeboard

Chromium and Hexavalent Chromium

Sodium, Calcium, Zinc, and Magnesium

All testing and sample analysis was done following accepted methodologies, such as EPA

Method 306 and 306A. In order to obtain data quality assurance and control, formal Quality

Assurance Project Plans (QAPs) were developed in input from the stack testing firms. The QAPs

have data quality objectives for:

duplicate analysis of both inlet and outlet stack samples and impinger blanks

duplicate sample percentage difference

instrument calibration percentage difference

analysis of standard sample

calibration and re-calibration of test and air sampling equipment

spiked samples and blanks for hexavalent chromium samples

serial dilution and/or spiking of samples and blanks for total chromium samples

duplicate sampling for above-tank fugitive emissions sampling.

For additional information on the QAPs and Quality Assurance Report, see Contact Information

in Appendix F.

In order to get an idea of the then-current emission levels prior to Method 306 testing,

Envisage Environmental, Inc., performed modified Method 306 on October 6,1995. (Modified

in that only one, one-hour test was performed instead of three, one-hour tests.) The results are

summarized in Table 4.

1/20/98
Table 4: Modified Method 30fi Test Results, Hexavalent Chromium in mc/dscni

Control Device

dual meshpad mist eliminator

tri-meshpad mist eliminator

Hexavalent

Chromium, mg/dscm

0.006

None Detected

Chromium MACT Standard Limit

for "Small" Facilities,

mg/dscm

0.03

0.03

The "preliminary" results indicated that these two sources had good probability of being in

compliance with the Chromium MACT Standard.

From October 18-19, 1995, Midwest Research Institute (MRI) conducted Method 306

testing at the inlet and outlet of the dual meshpad mist eliminator. From October 20 21, 1995,

Method 306 was conducted at the inlet of the tri-meshpad mist eliminator, while Method'306 and

Method 306A testing was conducted at the outlet. (Note: The EPA developed Method 306 and

306A for the determination of chromium emissions. Either method may be used). In addition,

other testing and data collection, as specified in the Baseline Test Plan, were performed.

Chromium air concentrations above the electroplating baths were conducted using OSHA

125-G procedures for total chromium. For the purposes of this project, the above-tank chromium

air concentration is measure of the emissions above the top of the exhaust hood slots that are

assumed not to be captured by the exhaust hood. The concentration values were not intended to

be measure of worker exposure levels.

The concentrations were measured approximately four inches above the top of the

electroplating tank exhaust hood or tank lip at three equidistant points (1/4, 1/2 and 3/4 of the

length of the tank's long axis) along line drawn down the middle of the tank paralleling the

long axis. membrane filter probe connected to personal sampling pump was placed in the

middle of each third of the centerline of the tanks. The probes were placed approximately one

foot above the plating tank's surface. The parts in the tanks were typically placed along the

centerline of the tanks. As stated previously, both the dual and the tri-meshpad mist eliminator

devices are ducted to push-pull single-sided lateral exhaust hoods.

Sampling was conducted for two-hour time period using personal sampling pumps

connected to 37-millimeter diameter and 0.8-micrometer-sized mixed cellulose-ester filter

cassettes. The filter cassettes were suspended so that the inlet was approximately four inches

above the exhaust hood slot.

Electroplating bath density measurements were done using ASTM Method 1298. SW846 Method 6010, ICP was used for multi-metals analysis of the baths. The industry standard

ritration method was used for the determination of hexavalent chromium concentration in the

electroplating bath samples. Chain of custody forms were completed for all samples submitted to

laboratories for analysis.

1/20/98
VIII. Results and Discussion of Results

Baseline testing results were received from MRI in January, 1996. Appendix contains

the Method 306 test results, while Appendix contains the Method 306A results. Additional

baseline test results can be found in Appendix C. The following text summarizes the major

findings.

A. Outlet Hexavalent Chromium Emissions

Table lists the outlet hexavalent chromium emissions results for both devices tested.

These results may be used to determine compliance with the Standard. (Note: The EPA allows

for the reporting of either hexavalent or total chromium.)

Table 5: Test Results for Outlet

PPI Control Device

Dry, dual-meshpad mist

eliminator

Wet, tri-meshpad mist

eliminator

iexavalent Chromium Emissions

10/95 Test Results

for Outlet

Hexavalent:

Chromium

(mg/dscm)

■0.0062

0.0030

Chromium MACT

Standard Limit for

-■' "small" facility

source

(mg/dscm)

0.03

0.03

EPA AP-42

expected outlet

concentration

range

(mg/dscm)

0.03 0.04

0.006-0.01

Test results indicate that hexavalent chromium emissions from both the dry, dual

meshpad mist eliminator and the wet, tri-meshpad mist eliminator are lower than the Standard's

limit. In fact, the levels are significantly lower than both the MACT.Standard limit and the EPA

AP-42 expected outlet concentration range for the control devices.

In January of 1996, the PPI Performance Testing Report was sent to the local Ohio EPA

air emissions division. In addition, PPI assisted in the development and implementation of its

Operation and Maintenance Plan.

B. Comparison of Method 306 and Method 306A

Table is comparison of the October, 1995 PPI tri-meshpad device Method 306,

Method 306A and 1990 Early Method 306A test results.

Table 6: Method 306 Method 306A Comparison, Hexavalent Chromium Results

PPI Control Device EPA Method 306

(October, 1995)

mg/dscm

EPA Method 306A

(October, 1995)

mg/dscm

Early Method 306A

(September, 1990)

mg/dscm

tri-meshpad mist

eliminator

0.005 0.007 0.013

10

1/20/98
Test results at this site and one in Michigan indicate that both EPA Method 306 and EPA

Method 306A, when done correctly, can produce results that are similar in chromium

concentration.

It was noticed that the Method 306A and the early Method 3O6A test runs had more

variation than the Method 306 test runs. Method 306A and early Method 306A hexavalent

chromium results have standard deviation 11 to 12 times the standard deviation of Method 306

hexavalent chromium results. Although the reason for this is still unclear, it can be noted that if

the highest value from each Method 306A and early Method 306A is excluded, the results are

closer (see Table 6A). This would indicate that the Method 306 and Method 306A results are

comparable and that the early Method 306A result is approximately two times more than the

Method 306 or Method 306A values. One possible explanation for this may be difference in

tank loading between the Method 306/Method 306A testing in October, 1995 and the early

Method 306A testing in September, 1990.

Table A: Method 306 Modified Method 306A Comparison, Hexavalent Chromium Results

PPI Control Device EPA Method 306

mg/dscm

EPA Method 306A

mg/dscm

Early Method 306A

mg/dscm

tri-meshpad mist

eliminator

0.005 0.005 0.011

C. Prevention/Control Device Efficiency

Table 7 contains the calculated "removal efficiency" and "milligrams of hexavalent

chromium/ampere-hour values" for the dual and tri-meshpad devices. Percent removal efficiency

is calculated using the following equation:

removal efficiency (inlet outlet chromium concentration)/inlet chromium concentration)

100

Table 7; Device Percent Efficiency and mg/Amp-hr for Hexavalent Chromium

Control Device Percent Efficiency mg/Amp-hr

dual-meshpad mist eliminator 99.8 0.015

tri-meshpad mist eliminator 99.96 0.010

In comparing removal efficiency test results from the five sources studied in the CSI

project, it was observed that removal efficiency only grossly correlated with the outlet

concentration of device. In fact, based on testing conducted to support the Standard, it was

found that removal efficiency is correlated to the log of inlet chromium concentration and is not

related to the outlet chromium concentration. The results of the five sources confirm this

finding.

D. Above-Tank Total Chromium Air Concentrations

The results of this study can be found in Table 8.

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1/20/98
Table 8: Above-Tank Chromium Air Concentrations, in

Source

Tank with dual-meshpad mist

eliminator

Tank with tri-meshpad mist

eliminator

Run No.

1.3308

9.9924

g/cubic meter

Run No.

0.8914

3.3605

Run No.

0.8142

2.6966

Average

1.0121

5.3498

Compared to the other tested sources in both Ohio and Michigan, the dual-meshpad

device results were roughly in the same range. The high above-tank concentrations for the trimeshpad unit may have been due to the placement of the filter cassette inlet, which was placed

such that it may have been below the air stream coming from the push header. This would mean

that the inlet was not above the top of the slot and was instead below it. The expected result

would be higher above-tank total chromium air concentration.

E. Prevention/Control Device Inlet Hexavalent Chromium Concentrations

The"prevention/control devices' inlet hexavalent chromium air concentration represents

air concentration without the use of prevention/control techniques. Test results can be found in

Table 9.

Table 9: "inlet Hexavalent Chromium Concentrations, mg/dscm

Source Inlet Hexavalent Chromium, mg/dscm

dual meshpad mist eliminator 4.57

tri-meshpad mist eliminator 11.53

The tri-meshpad unit's inlet concentration was much higher than the dual meshpad unit's,

even though the part-loading and the amp-load of both units was similar during testing.

F. Freeboard

Table 10 lists the freeboard measurements obtained during the October, 1995 testing at

PPI. Freeboard is measurement of the distance between the plating bath surface level and the

bottom of the exhaust hood slot.

Table 10: Freeboard _____

PPI Control Device Freeboard, cm. (in.)

Dual-meshpad mist eliminator 20.3 (8.0)

Tri-meshpad mist eliminator 15.2 (6.0)

Recent industry studies have sought to offer some insight into the effect of freeboard on

fugitive emissions. In one study, researchers concluded that freeboard of 15 cm (about

inches) will result in the lowest emissions, and freeboards of either less or more than 15 cm

would result in greater emissions. In another study, it was noted that increasing the freeboard

from 15.2 cm (6 inches) to 30.5 cm (12 inches) did not have significant effect on fugitive

emissions.

12

1/20/98
The other four sources being studied had freeboard values in the 5- to 12-inch range.

When freeboard was varied for one of the sources, there was not significant effect on emission

levels. Accordingly, no correlation can be drawn from this study.

G. Ventilation Rates

The OSHA minimum and test ventilation rates were calculated and appear in Table 11.

The method for calculating the minimum ventilation rate is found in 29CFR 1910.94.

Source

Tank with dual meshpad mist eliminator

Tank with tri-meshpad mist eliminator

Tank Area

sq. ft

20

20

OSHA Minimum

cfm

1.500

1,500

Test cfm

4,319

4,950

For both PPI sources, the OSHA minimum ventilation rate requirement was more than

satisfied. Due to their operational features, push-pull hoods, such as those at PPI, capture more

fugitive emissions and are therefore more effective in reducing worker exposures. However, the

additional emissions captured will have to be controlled by the prevention/control device in order

for the unit to meet the Standard, as they are in PPI's case.

IX. PPPs Pollution Prevention Features

The following PPI process features constitute industry standard pollution prevention

techniques:

Countercurrent Rinsing

Countercurrent rinsing employs sequential rinse tanks in which the rinsewater flows in

the opposite direction of the workpiece flow. Fresh water is only added to the final rinse tank

and is transported, usually by gravity overflow, to the previous rinse tank. Wastewater exits the

system from the first rinse tank. In some cases (e.g., PPI's), this wastewater can be used as

plating bath make-up. Many shops have used this technique to minimize water consumption. In

fact, reductions of up to 95% have been reported. The following drawing depicts three-stage

countercurrent rinse system.

Workpiece Movement

r~

Workpiece

Process

Tank

Rinse

Tank

Rinse

Tank

Rinse

Tank

Effluent to

Recovery or Treatment

Rinsewater

Influent

13

1/20/98
Spray Rinsing

PPI has installed rinse spray nozzles over an empty tank to replace an entire rinse tank

filled with water. The overspray is then be returned to the process bath, resulting in reduced

plating bath drag-out. Some metal finishing shops have reported using 10 25% less water with

spray rinsing compared to dip rinsing.

Close-Looped Rinsing System

PPI's facility is serviced by septic tank system, which helped to influence their decision

to close-loop their liquid material flows. All liquids are managed in such way that they are

reused in the process and not sent to the septic tank. For example, all meshpad washwaters, and

all rinsewaters are reused and eventually returned to the process baths.

Secondary Containment

During the construction of their plating facility, PPI excavated large section of the

concrete floor in order to build their secondary containment system. They then installed lining

encased in concrete walls, and coated the space with chemical-resistance sealer. Finally, the

process and rinse tanks were lowered in the containment space. PPI's system will provide

secondary containment for any and all spills and leaks, including catastrophic situation where

all of the tanks would be ruptured or leaking.

X. Conclusions

Dry, dual meshpad, and wet, tri-meshpad mist eliminator prevention/control devices are

capable of meeting the Chromium MACT Standard for both EPA "small" and "large" facilities.

In fact, they can effectively control chromium emissions and discharges due to the following

features:

1. The meshpad mist eliminator design and operation does not solve air emission

problems at the expense of water discharge problems.

2. Only small amount (typically 7-10 gallons/day) of chromium-bearing fluid is

generated during operation and cleaning processes. This fluid can be returned to the

plating tank in almost all instances.

3. The equilibrium concentration of chromium in the re-circulated fluid remains low

enough that it can be used for extended periods, rather than building up continuously

with use.

4. The chromium concentration in the re-circulated fluid can be used to gauge the

effectiveness of the first (primary) meshpad.

5. No waste pretreatment systems are needed.

6. Meshpads are able to be removed for cleaning, inspection, repair and replacement.

7. The meshpad configuration can be modified to influence emission control.

XI. Post-Project Summary

Although not surprised by the test results, PPI was pleased with their compliance status

and the assistance that they had received as result of this Project. In addition, as result of the

14

1/20/98
distribuUon of Project results to the plating industry, hard chrome platers now have proven

option for complying with the Chromium MACT Standard.

XII. Responsibilities and Funding

Project responsibilities were assigned as follows:

ActivitY/Iten

Baseline Testing

Operations and Maintenance Manual

Project Report

Responsible Partv(ies)

CAMP/GLMTC

PPI, CAMP/GLMTC

CAMP/GLMTC

Project funding was contributed as follows:

Project Participant

CAMP/GLMTC

USEPA- Design for the

Environment

Plating Perceptions, Inc.

TOTAL

EEM/TRP-CSI Funds

$6,900

$4,800 project management

$2,100 report preparation

$6,900

In-Kind Contributions

$50,000

baseline testing -10/95

$3,250

65 hours $50/hour for

project activities

$53,250

15

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REFERENCES

1. Subpart National Emissions Standardsfor Chromium Emissions from Hard and

Decorative Chromium Electroplating and Chromium Anodizing Tanks, 40CFR Parts and

63.

2. Hard Chrome Pollution Prevention Demonstration Project Interim Report, USEPA

Common Sense Initiative Metal Finishing Subcommittee/National Institute of Standards and

Technology Manufacturing Extension Partnership, November 27,1996

3. Hexavalent Chrome Emission Testing Program: Assisting Metal Finishers in Meeting the

1995 Chrome MACT Standard, James E. Hensley, et. al., Industrial Technology Institute,

1996.

4. ChromeTech, Inc., P.O. Box 295, Windsor, Ohio, 44099.

5. Chromium Emissions from Chromium Electroplating and Chromic Acid Anodizing

Operations-Background Information for Proposed Standards, Volume II, USEPA, Research

Triangle Park, NC, EPA 453/R-93-030b, July, 1993.

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Appendix A: SUMMARY OF BASELINE METHOD 306

CHROME DEMO TESTS

Baseline Conditions

Device

dual

mesh pad

Run

No.

Test Parameters

Amphr/Hr

2690

2598

3646

Outlet Air

Flow,

dscm/min

123

124

120

Run

Time

(miu)

120

120

120

Test Chromium Concentration

Inlet

Hex,

ma/M3

1.2932

5.8476

6.5651

Inlet

Total,

1.190

6.020

6.810

Outlet

Hex,

me/M3

0.0049

0.0040

0.0097

Outlet

Total,

0.0162

0.0150

0.0192

AboveTank,

mc/MJ

1.3308

0.8914

0.8142

tri-meshpad 2176

2354

3005

135

137

139

120

120

120

8.1134

14.8243

11.6571

9.020

13.700

11.00

0.0028

0.0030

0.0032

0.0169

0.0190

0.0087

9.9924

3.3605

2.6966

17

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Appendix B: SUMMARY OF BASELINE METHOD 306A

CHROME DEMO TESTS

Baseline Conditions

Device

tri-mesh pad

Run

No.

Test Parameters

Amphr/Hr

2176

2354

3005

Outlet Air

Flow, dscm

135

137

139

Run

Time

(min)

120

120

120

Test Chromium Concentration

Inlet

Hex,

mg/M3

8.1134

14.8243

11.6571

Inlet

Total,

mg/M3

9.020

13.700

11.000

Outlet

Hex,

mg/M3

0.0025

0.0041

0.0076

Outlet

Total,

mg/M3

0.0172

0.0342

0.0245

AboveTank,

ma/M3

9.9924

3.3605

2.6966

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1/20/98
Appendix C: ADDITIONAL BASELINE TEST RESULTS

Parameter Results

Source with Dual

Meshpad Unit

Source with TriMeshpad Unit

Bath Concentrations:

Zinc (Hg/ml)

Calcium (p.g/ml)

Magnesium (u,g/ml)

Sodium (ixg/ml)

Chromium (jig/ml)

Chromic Acid (oz/gal)'

329.8

460.0

574.4

4,283

111,570

27.33

509.7

928.8

1100

8,238

148,850

40.48

Surface Tension (dynes/cm):

Apparent

Corrected

Density (g/ml)3

Pressure Drop Across Device

66.2@83.9

62.8

1.1621

3.5 inches water

71.5@85.OF

67.8

1.2381

5.7 inches water

Average of two titrations.

Using surface tension correction factor of 0.94 and temperature correction factor of 0.14

dynes/cm*C); corrected to 25 C.

Readings taken at room temperature of 23.5 C, not corrected to 15 C.

Average of three runs.

19

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Appendix D: GLOSSARY OF TERMS

Add-on air pollution control device: Equipment installed in process for the purposes of

collecting and containing air emissions.

Air emission prevention/control technique: Any method, such as an add-on air pollution control

device or chemical mist (fume) suppressant, which is used to reduce emissions.

Chemical mist suppressant: Any chemical agent that reduces or suppresses fumes or mists at the

surface of an electroplating or anodizing bath. Another term of chemical mist suppressant is

fume suppressant.

Chromic acid: The common name for chromium anhydride (CrO3>.

Chromium anodizing: The electrolytic process by which an oxide layer is produced on the

surface of base metaffor "functional purposes (e.g., corrosion-resistance) using chromic acid

solution.

Composite meshpad system: An add-on air pollution, control device typically consisting of

several meshpad stages. The purpose of the first stage is to remove large particles. Smaller

particles are removed in the second stage, which consists of composite meshpad. final stage

may remove any re-entrained particles not collected by the composite meshpad.

Decorative chromium electroplating: The process by which thin layer of chromium (typically

0.003 to 2.5 microns) is electrodeposited on base metal, plastic, or undercoating to provide

bright surface with wear and tarnish resistance. This chromium process can involve either the

trivalent or hexavalent form. Typical current density applied to this process ranges from 50 to

220 amperes per square foot for total plating times ranging from 0.5 to minutes.

Electroplating or anodizing bath: The electrolytic solution used as the conducting medium in

which current is accompanied by movement of metal ions for the purposes of electroplating

metal out of the solution onto workpiece or for oxidizing the base metal.

Emission limitation: The concentration of a chemical permitted to be emitted.

Existing tank: Under the Chromium MACT Standard, tank having startup date prior to

December 16, 1993.

Fiber-bed mist eliminator. An add-on air pollution control device that removes contaminants

from gas stream through the mechanisms of inertial impaction and Brownian diffusion.

Hard chromium electroplating: process by which thick layer of chromium (typically 1.3 to

760 microns) is electro-deposited on base material to provide surface with functional

properties such as wear-resistance, low coefficient of friction, hardness, and corrosionresistance. The hard chromium electroplating process is performed using current densities

20

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typically ranging from 150 to 600 ampere per square foot for total plating times ranging from 20

minutes to 36 hours, depending upon the desired plate thickness.

Hazardous air pollutant: Title III of the Clean Air Act Amendments identifies 189 substances

are hazardous air pollutants (HAPs). Under Title III, sources that emit one or more HAPs may be

required to comply with Maximum Achievable Control Technology (MACT) Standards. These

Standards will be based upon the best demonstrated control technology or practices used by the

regulated industry.

Large, hard chromium electroplating facility: facility that performs hard chromium

electroplating and has maximum cumulative potential rectifier capacity greater than or equal to

60 million ampere-hours per year.

Maximum Achievable Control Technology (MACT): Emission limitations based on the best

demonstrated control technology or practices applied to major sources emitting one or more of

the federally-listed hazardous air pollutants.

National Ambient Air Quality Standards (NAAQS): Air quality standards established by the EPA

that apply to outside air throughout the country.

National Emission Standards for Hazardous Air Pollutants (NESHAPs): Emission standards set

by the EPA for air contaminants not covered by NAAQS that may cause an increase in deaths, or

serious irreversible or incapacitating illnesses.

New tank: Under the Chromium MACT Standard, tank with startup date after December 16,

1993.

Packed-bed scrubber. An add-on air pollution control device consisting of single or double

packed-bed that contains packing media on which chromic acid droplets impinge. The packedbed system is followed by mist eliminator which removes any water entrained from the packedbed section. When using this type of control method, fresh water must be added from the top in

order to meet the Chromium MACT Standard.

Reconstructed tank: Under the Chromium MACT Standard, tank in which the replacement of

tank components was to the extent that the fixed capital cost of the new components exceeded

50% of the fixed capital cost that would be required to construct comparable new tank, and it is

technologically and economically-feasible for the tank to meet the requirements of the Standard.

Rectifier. device that converts alternating current into direct current by permitting

considerable flow of current in one direction.

Small hard chrome plating facility: facility that performs hard chrome electroplating

and has maximum cumulative potential rectifier capacity less than 60 million amperehours/year.

21

1/20/98
Stationary source: Any building, structure, facility, or installation that emits or may emit any air

pollutant.

22

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Appendix E: ABBREVIATIONS USED IN THIS DOCUMENT

AESF

A/ft2

Amp

Amp-hr

Amp-hr/Hr

AP-42

ASTM

CAAA

cfm

CFR

cm

CMP

CSI

DfE

DoE

dscf

dscm

EPA

ft

ft2

ft3

GLMTC

HAP

Project

hr

ICP

in

m2orM2

m3orM3

MACT

MEP

MFSA

mg

min

MRI

NAMF

NESHAP

NIST

NRMRL

OAQS

OU

ORD

The American Electroplaters and Surface Finishers Society, Inc.

ampere per square foot

ampere

ampere-hour

ampere-hour/hour

USEPA's publication of emission factors for various industries

The American Society of Testing and Materials

Clean Air Act Amendments

cubic feet per minute

Code of Federal Regulations

centimeters

composite meshpad

Common Sense Initiative

USEPA's Design for the Environment

Department of Energy

dry standard cubic foot

dry standard cubic meter

Environmental Protection Agency

foot

square foot

cubic foot

Great Lakes Manufacturing Technology Center

hazardous air pollutant

The Hard Chrome Pollution Prevention Demonstration Project

hour

Inductively Coupled Plasma Emission Spectrometry

Industrial Technology Institute

meter

square meter

cubic meter

Maximum Achievable Control Technology

Manufacturing Extension Partnership

The Metal Finishing Suppliers Association

milligram

minute

Midwest Research Institute

The National Association of Metal Finishers

National Emission Standards for Hazardous Air Pollutants

The National Institute of Standards and Technology

The USEPA's National Risk Management Research Laboratory

The USEPA's Office of Air Quality Planning and Standards

The DoE's Office of Industrial Technologies

The USEPA's Office of Research and Development

23

1/20/98
OSHA Occupational Health and Safety Administration

P2 Pollution Prevention

PBS Packed Bed Scrubber

QAPs Quality Assurance Project Plans

SW-846 Standards Methods for Environmental Testing

USDoE United States Department of Energy

USEPA United States Environmental Protection Agency

24

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Appendix F: CONTACT INFORMATION

Organization

Industrial

Technology Institute

(ITI)

CAMP, Inc.

Title

Manager,

Environment/Energy

Department

Manager, Manufacturing

Environmental

Management Services

Address

2901 Hubbard Rd.

P.O. Box 1485

Ann Arbor, MI

48105-1485

4600 Prospect Ave.

Cleveland, OH

44103

Phone/Fax

Numbers

313-769-4087 (p)

313-769-4064(f)

216-432-5300 (p)

216-361-2900 (f)

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