DRAFT 

DATE: August 16, 2010 

SUBJECT: Section 112(d)(6) Technology Review for Chromium Electroplating NESHAP 

Emission Standards Technical Support and Post Promulgation Activities 

EPA Contract No. EP-D-06-118; EPA Work Assignment No. 4-6 

RTI Project No. 0210426.004.006 

FROM: Richard Marinshaw 

TO: Phil Mulrine, EPA/OAQPS/SPPD/MMG 

The purpose of this memorandum is to present the results of a review of available 

information on developments in practices, processes, and control technologies that apply to 

chromium electroplating, and specifically to sources subject to the national emission standards 

for hazardous air pollutants (NESHAP) for Hard and Decorative Chromium Electroplating and 

for Chromium Anodizing Tanks (40 CFR 63, subpart N). This analysis is part of the U.S. 

Environmental Protection Agency’s (EPA’s) review efforts in accordance with section 112(d)(6) 

of the Clean Air Act (CAA). Section I of this memorandum provides background information on 

the requirements of section 112(d)(6) of the CAA, the chromium electroplating source category, 

and the requirements of the Chromium Electroplating NESHAP. Section II discusses the review 

of information on developments in practices, processes, and control technologies that have 

occurred since the original development of this NESHAP. 

I. Background/Purpose 

A. Requirements of Section 112(d)(6) of the CAA

Section 112 of the CAA requires EPA to establish technology-based standards for 

sources of hazardous air pollutants (HAP). These technology-based standards are often referred 

to as maximum achievable control technology, or MACT, standards. Section 112 also contains 

provisions requiring EPA to revisit these standards. Specifically, paragraph 112(d)(6) section 

states: 

(6) REVIEW AND REVISION. – The Administrator shall review, and revise as 

necessary (taking into account developments in practices, processes, and control 

technologies), emission standards promulgated under this section no less often 

than every 8 years. 
2 

For the purpose of this technology review, a “development” was considered to be any of 

the following: 

• Add-on control technology or other equipment that was not identified and considered 

during the development of the NESHAP; 

• Improvements in add-on control technology or other equipment that were not identified 

and considered during NESHAP development that could result in significant additional 

HAP emissions reductions; 

• Work practice or operational procedure that was not identified and considered during 

NESHAP development; and 

• Process change or pollution prevention alternative that could be broadly applied that was 

not identified and considered during the development of the NESHAP. 

B. Description of Source Category and NESHAP Requirements

Electroplating is the process of applying a metallic coating to a surface by passing an 

electric current through an electrolyte that is in contact with the surface. Electroplating typically 

is performed in a tank containing the electrolytic solution or bath, and the part or surface that is 

to be plated is immersed in the solution while an electric current is applied. A wide range of 

metals are electroplated on a commercial scale, with the most common including cadmium, 

chromium, copper, gold, lead, nickel, silver, tin, and zinc. The Chromium Electroplating 

NESHAP applies only to those processes that use chromic acid in an electrolytic cell to deposit 

chromium metal or to form an oxide film on a surface, part, or product. Specifically, the 

NESHAP covers three types of processes: hard chromium electroplating, decorative chromium 

electroplating, and chromium anodizing. 

In hard chromium electroplating, a relatively thick layer of chromium is deposited 

directly on a base metal (usually steel) to provide a surface with wear resistance, a low 

coefficient of friction, hardness, and corrosion resistance. In decorative chromium 

electroplating, the base material generally is plated with a layer of nickel followed by a relatively 

thin layer of chromium to provide a bright surface with wear and tarnish resistance. In 

chromium anodizing, also referred to as chromic acid anodizing, chromic acid is used to form an 

oxide layer on aluminum to provide corrosion resistance. Chromium anodizing is used primarily 

on aircraft parts and architectural structures that are subject to high stress and corrosive 

conditions. Plating operations range in size from small shops, with one or two small tanks that 

are operated only a few hours per week, to large shops, with several large tanks that are operated 

continuously. 

During electroplating and anodizing operations, hydrogen and oxygen evolve on the 

outside of submerged parts or on anodes or cathodes. As the gas bubbles rise to the surface of 

the electroplating bath, they burst, creating emissions in the form of a fine mist. Air sparging 

(mixing of tank bath) also can result in emissions from the bursting of air bubbles at the surface 

of the plating tank liquid. The bursting of air bubbles at the tank surface is the mechanism for 

emissions from chromium electroplating. 
3 

The principal techniques used to control emissions from chromium electroplating and 

anodizing tanks can be categorized as either add-on control devices or fume suppressants. Addon controls require the tank to be equipped with a ventilation system, consisting of a hood, 

ductwork, and exhaust fan, to capture emissions and direct the emissions stream to the control 

device or stack. The most common add-on control devices for chromium electroplating 

operations are mist eliminators and wet scrubbers. Fume suppressants, which are used in the 

electroplating tank, can be used regardless of whether or not the tank is equipped with a 

ventilation system. Fume suppressants reduce emissions by either lowering the surface tension 

of the plating bath or by creating a cover on the bath that inhibits the formation of mists. 

 

The Chromium Electroplating NESHAP, which was promulgated on January 25, 1995 

(60 FR 4948) regulates chromium emissions from new and existing hard and decorative 

chromium electroplating and chromium anodizing tanks at major and area sources. To comply 

with the NESHAP, owners and operators of affected sources can either meet a chromium 

emissions concentration limit, or an electroplating bath surface tension limit. When first 

promulgated, the surface tension limit was an option for decorative chromium electroplating and 

for chromium anodizing, but not for hard chromium electroplating. The NESHAP also specifies 

work practice standards, initial performance testing, ongoing compliance monitoring, 

recordkeeping, and reporting requirements. 

 Amendments to the Chromium Electroplating NESHAP were promulgated on July 19, 

2004 (69 FR 42885). The amendments extended the surface tension limit to hard chromium 

electroplating tanks – under the original NESHAP, the surface tension limit option applied only 

to decorative chromium electroplating and chromium anodizing tanks. The amendments also 

revised the surface tension limit when measured with a tensiometer; established a procedure for 

determining an alternate emission limit for hard chromium electroplating tanks equipped with 

enclosing hoods; revised definitions for chromium electroplating and chromium anodizing tanks; 

and revised the monitoring requirements for a specific type of control system. 

II. Practices, Processes, and Control Technologies for Chromium Electroplating 

A. Control Technologies Considered for NESHAP

 Table 1 summarizes the practices, processes, and control technologies considered during 

the development of the Chromium Electroplating NESHAP. The emission limits developed for 

hard chromium electroplating tanks were based on the levels of chromium emissions control 

achieved using composite mesh pads; for decorative chromium electroplating and chromium 

anodizing tanks, the emission limits were based on the use of wetting agent fume suppressants 

(WAFS) for controlling emissions. 

 
4 

Table 1. Summary of Controls Considered in Development of NESHAPa

General Category Technology Examples 

Add-on control Mist eliminator Composite mesh pad 

Mesh pad mist eliminator 

Fiber bed mist eliminator 

Chevron blade mist eliminator 

Wet scrubber Single or double packed bed scrubber 

Fan separator packed bed scrubber 

Centrifugal flow scrubber 

Fume suppressant Chemical Wetting agent fume suppressant (WAFS) 

Foam blanket 

Physical Plastic balls 

Other floating media a

 Reference 1. 

 B. Technology Developments Since Promulgation of NESHAP

 Since the NESHAP was promulgated in 1995, there have been several developments in 

the methods for controlling emissions from chromium electroplating tank. The following 

paragraphs describe these developments. 

WAFS for Hard Chromium Electroplating

When the NESHAP was promulgated, using a WAFS without an add-on control device 

was not considered to be a viable option for meeting the emission limits for hard chromium 

electroplating tanks. However, based on recommendations made by the Common Sense 

Initiative (CSI) Metal Finishing Subcommittee and research conducted by EPA’s Office and 

6Research and Development (ORD), it was concluded that compliance with the emission limits 

can be achieved when a WAFS is used to reduce the surface tension below certain levels. This 

development was addressed in the 2004 amendments to the NESHAP. 

Instrumental Differences in Surface Tension Measurements

The research performed by ORD also showed differences in electroplating bath surface 

tension, depending on the type of instrument used; measurements made using a stalagmometer in 

the range of the compliance value of 45 dynes per centimeter (dynes/cm) were typically about 

10 dynes/cm higher than measurements made using a tensiometer. To account for this difference 

a provision was included in the 2004 amendments specifying 35 dynes/cm as the compliance 

level when a tensiometer is used to measure surface tension. 

Enclosing Tank Hoods

A significant development in electroplating tank design occurred with the introduction of 

state-of-the-art plating tanks that feature enclosing hoods that completely cover the surface of the 

plating tank. The covered tank design allows for effective capture and ventilation at 

substantially lower ventilation rates than otherwise encountered with more conventional 
5 

hooding. However, because the NESHAP emission limits are in the format of an emission 

concentration standard, it was very difficult for some owners and operators to meet the emission 

limits. This problem was addressed in the 2004 amendments by including a provision for an 

alternative mass rate emission limit for these sources. 

Emission Elimination Devices

 Another development in controlling emissions from chromium electroplating tanks was 

the introduction of the emission elimination device (EED), which is also referred to as a Merlin 

cover. This device consists of a tank cover that includes a porous membrane, which allows gases 

to escape, but captures droplets and mist emanating from the electroplating tank. The EED has 

not gained wide acceptance, largely because it often is not practical to cover the electroplating 

tank while plating is underway. Although the NESHAP does not specifically address the use of 

EEDs, §63.343(d) of the rule allows owners or operators of affected tanks to apply for case-bycase approval. For this reason, and the fact that these devices are not widely used, it is not 

recommended that the NESHAP be amended to address EED’s. 

HEPA Filters

 A high efficiency particulate air (HEPA) filter is an air filtering device that contains a 

mat of randomly-arranged fibers specifically designed to remove at least 99.97 percent of 

airborne particles that are 0.3 micrometers or larger in diameter. Although HEPA filters had 

been on the market for decades, they were not considered as a practical control method for 

electroplating tank emissions when the NESHAP was developed. The fine mesh of a HEPA 

filter would quickly clog up if subjected to chromium electroplating emissions, and there were 

several other types of mist eliminator technologies that had been proven to be effective for 

electroplating emissions. However, in the past decade, facilities in California have increasingly 

used HEPA filters to meet the emission limits of the state's Airborne Toxic Control Measure 

(ATCM) for Chromium Plating and Chromic Acid Anodizing Facilities. In October 2007, the 

California Air Resources Board (CARB) amended the ATCM to further tighten emission limits 

and to require HEPA filters on all new chromium electroplating and anodizing tanks. In these 

applications, HEPA filters act as a second stage of control, with the first stage generally 

consisting of a mesh pad mist eliminator or other device that first removes all of the large 

particles prior to the HEPA filter. 

 As part of this technology review, HEPA filters have been considered as a possible 

control option for sources subject to the Chromium Electroplating NESHAP. An analysis of the 

emissions reductions and annualized control costs has been performed and is addressed in a 

separate memorandum, Emissions Reductions and Cost Effectiveness of HEPA Filters for 

Chromium Electroplating Sources. 

CARB ATCM

 As mentioned in the previously, CARB amended their Chromium Electroplating ATCM 

in October 2007. The amendments made several significant changes to the rule, including more 

stringent emission limits, the requirement to install HEPA filters on new chromium 
6 

electroplating tanks, restrictions on the location of new chromium electroplating facilities, 

housekeeping procedures for reducing fugitive emissions of chromium-laden dust, and 

procedures for using a stalagmometer for measuring electroplating bath surface tension. A more 

detailed list of the major changes to the ATCM is included in Attachment 1. 

 After considering the changes to, and current requirements of, the ATCM, the decision 

was made to propose the following as a result of this technology review: 

• Amending the Chromium Electroplating NESHAP to incorporate housekeeping 

procedures, and 

• Amending Method 306B to include procedures for using stalagmometers for 

measuring surface tension. 

In both cases, the proposed procedures are based on the requirements specified in the ATCM. 

The proposed housekeeping procedures would help to minimize fugitive emissions of chromiumladen dust, and the proposed procedures for stalagmometers would help to ensure that the surface 

tension limits specified in the NESHAP are being maintained. As noted previously, the costs 

and emissions reductions associated with requiring HEPA filters on chromium electroplating 

tanks also were evaluated. 

PFOS-based Fume Suppressants

 

 Wetting agent fume suppressants are used in most decorative chromium electroplating 

and chromium anodizing tanks and in many hard chromium electroplating tanks for emission 

control. Historically, the most effective types of WAFS have been based on perfluorooctane 

sulfonic acid (PFOS). These compounds are part of a family of chemical compounds 

categorized as long-chain perfluorinated chemicals (PFCs). As noted in EPA’s Long-Chain 

Perfluorinated Chemicals Action Plan, these compounds have persistent, bioaccumulative, and 

toxic (PBT) characteristics and are a particular concern for children’s health.2

 Although it has 

not been demonstrated that these compounds cause adverse effects to humans, studies have 

shown significant adverse effects to laboratory animals and wildlife. As a result, EPA intends to 

address the potential risks from this family of compounds by 2012 under the Toxic Substances 

Control Act. 

 The non-PFOS fume suppressants currently available can generally be classified as 

anionic fluorinated surfactants. These compounds contain six fluorinated carbons that cannot 

break down or decompose to PFOS. In addition, none of the components present in these 

compounds at concentrations equal to or greater than 0.1 percent are listed as carcinogens by the 

International Agency for Research on Cancer, the Occupational Safety and Health 

Administration, National Toxicology Program, or the American Conference of Governmental 

Industrial Hygienists as a carcinogen.3

 In view of the increasing concern over the presence of long-chain PFCs in the 

environment, and the fact that other types of WAFS are effective in chromium electroplating 

operations and are available at a reasonable cost, a phase-out of PFOS-based WAFS is being 

proposed as a result of this technology review. As currently planned, the phase-out would apply 
7 

to all long-chain PFOS used as a WAFS in hard chromium electroplating and decorative 

chromium electroplating. The phase-out would have an effective date 3 years after promulgation 

of the final amendments to the Chromium Electroplating NESHAP. Long-chain PFOS could 

continue to be used as a WAFS in chromium anodizing operations until such time as an effective 

substitute could be identified. 

 B. Search for Other Applicable Technology Developments 

 In addition to the information discussed above, searches of the RACT/BACT/LAER 

Clearinghouse and the Internet were conducted to identify other technologies or developments 

that could be applied to chromium electroplating. The results of these searches are described in 

the following paragraphs. 

RACT/BACT/LAER Clearinghouse4

 

 Under EPA’s New Source Review (NSR) program, if a company is planning to build a 

new plant or modify an existing plant such that air pollution emissions will increase by a large 

amount, the company must obtain an NSR permit. The NSR permit is a construction permit 

which requires the company to minimize air pollution emissions by changing the process to 

prevent air pollution and/or installing air pollution control equipment. 

 The terms “RACT,” “BACT,” and “LAER” are acronyms for different program 

requirements under the NSR program. RACT, or Reasonably Available Control Technology, is 

required on sources in areas that are not meeting national ambient air quality standards (i.e., nonattainment areas). BACT, or Best Available Control Technology, is required on major new or 

modified sources in attainment areas. LAER, or Lowest Achievable Emission Rate, is required 

on major new or modified sources in non-attainment areas. 

 BACT and LAER (and sometimes RACT) are determined on a case-by-case basis, 

usually by State or local permitting agencies. EPA established the RACT/BACT/LAER 

Clearinghouse, or RBLC, to provide a central database of air pollution technology information 

(including past BACT and LAER decisions contained in NSR permits) to promote the sharing of 

information among permitting agencies and to aid in future case-by-case determinations. 

However, data in the RBLC are not limited to sources subject to RACT, BACT, and LAER 

requirements. Noteworthy prevention and control technology decisions and information are 

included even if they are not related to past RACT, BACT, or LAER decisions. 

 The RBLC contains over 5,000 air pollution control permit determinations that can help 

identify appropriate technologies to mitigate most air pollutant emission streams. It was 

designed to help permit applicants and reviewers make pollution prevention and control 

technology decisions for stationary air pollution sources, and includes data submitted by several 

U.S. territories and all 50 States on over 200 different air pollutants and 1,000 industrial 

processes. 

 To identify technologies appropriate for chromium electroplating, searches of the RBLC 

were made using the Process Type field for the following Process Type Codes: 99.007 - Hard 
8 

Chromium Electroplating, 99.005 - Decorative Chromium Electroplating, and 99.002 - Chromic 

Acid Anodizing. All records from 1993 to 2010 were searched. No records were found for 

chromic acid anodizing. For hard chromium electroplating, the search identified information for 

two facilities. The electroplating tank controls used at those facilities included a wet scrubber 

and an EED (Merlin cover). For decorative chromium electroplating, the search also provided 

information on two facilities; at one facility, the tanks were controlled with a combination 

chevron blade mist eliminator, wet scrubber, and mesh pad. At the other facility, the control 

method is indicated as “decreased surface area of plating bath.” In all cases, the control devices 

and methods identified through the RBLC search do not represent new technologies that have not 

already been considered. Attachment 2 show the results of the RBLC search for hard chromium 

electroplating, and Attachment 3 shows the results for the decorative chromium electroplating 

search. 

Internet Search

 A general search of the Internet was conducted for information on control technologies 

for electroplating and anodizing tanks. The search identified a document prepared by CARB that 

provides a comprehensive review of the various technologies and practices used for controlling 

chromium emissions from electroplating and anodizing operations and for complying with the 

ATCM. This document (Chrome Plating and Anodizing Operations - 306 Emission Control 

Techniques), which is provided as Attachment 4, does not identify any control technologies not 

already considered for the original NESHAP or as part of this technology review. Likewise, 

none of the other documents and references located through the Internet search identified any 

new practices, processes, or technologies that have already been considered in this review. 

III. References 

1. Chromium Emissions from Chromium Electroplating and Chromic Acid Anodizing 

Operations – Background Information for Proposed Standards, Volume I (EPA 453/R-93-

030a). Office of Air Quality Planning and Standards. U.S. Environmental Protection 

Agency, Research Triangle Park, NC. July 1993. 

2. Long-Chain Perfluorinated Chemicals (PFC) Action Plan. Office of Pollution Prevention 

and Toxics, U.S. Environmental Protection Agency, Washington, D.C. December 20, 2009 

3. Email from C. Richter, The Policy Group to P. Mulrine, EPA/OAQPS. PFOS Phaseout. 

June 3, 2010. 

4. Technology Transfer Network, Clean Air Technology Center - RACT/BACT/LAER 

Clearinghouse. http://cfpub.epa.gov/rblc/index.cfm?action=Search.BasicSearch&lang=en.
Attachment 1 

Summary of October 2007 Amendments to California Airborne Toxic Control Measure for 

Chromium Plating and Chromic Acid Anodizing Facilities 

• Bans the sale or supply of chromium electroplating or anodizing kits to anyone other 

than a permitted facility 

• Requires existing facilities to: 

o Meet a more stringent emission limit of 0.0015 milligrams per ampere-hour 

(mg/A-hr) 

o Comply with the revised emission limits according to a phased-in schedule that 

ranges from 6 months to 3 years, depending on the facility's permitted throughput 

and the distance to sensitive receptors 

o Conduct a performance test to demonstrate compliance with emission limit 

o Keep in place any existing add-on control device unless the device is replaced 

with a control device that meets an emission limit of 0.0015 mg/A-hr 

o Conduct a site-specific risk assessment if annual emissions exceed 15 grams 

• For existing facilities located more than 330 feet from a sensitive receptor, and if the 

annual permitted hours are no more than 50,000 A-hr per year, the facility can: 

o Use a chemical fume suppressant instead of an add-on control device 

o Meet a electroplating bath surface tension limit that ranges from 28 to 40 dynes 

per centimeter (dynes/cm), depending on the specific fume suppressant and the 

instrument used to measure surface tension (stalagmometer or tensiometer) 

• Requires new facilities to: 

o Be located at least 1,000 feet from the boundary of any area zoned as residential 

or mixed use 

o Be located at least 1,000 feet from any existing school or school under 

construction 

o Install a HEPA filter to control emissions 

o Meet a more stringent emission limit of 0.0011 mg/A-hr 

o Conduct a performance test to demonstrate compliance with emission limit 

• Specifies housekeeping requirements for all facilities to minimize emissions of 

fugitive dust containing chromium 

• Specifies procedures for measuring electroplating bath surface tension using a 

stalagmomete
COMPREHENSIVE REPORT

Report Date:05/27/2010

Facility Information

RBLC ID: IN-0100 (final) Date Determination

Last Updated: 11/13/2003

Corporate/Company Name: AK STEEL CORPORATION Permit Number: 147-6713-00041

Facility Name: ROCKPORT WORKS Permit Date: 02/13/1997 (actual)

Facility Contact: FRS Number: 110017418329

Facility Description: STEEL COIL FINISHING PLANT; ALL POLLUTANTS IN PERMIT ARE

LISTED

SIC Code: 3316

Permit Type: A: New/Greenfield Facility NAICS Code: 331221

Permit URL:

EPA Region: 5 COUNTRY: USA

Facility County:

Facility State: IN

Facility ZIP Code: 47635

Permit Issued By: INDIANA DEPT OF ENV MGMT, OFC OF AIR (Agency Name) 

MS. NISHA SIZEMORE(Agency Contact) (317) 232-8356 NSIZEMOR@IDEM.IN.GOV 

Other Agency Contact Info: PAUL DUBENETZKY 

IN

317-232-8603

Permit Notes:

Process/Pollutant Information

PROCESS

NAME:

BOILERS (2), NATURAL GAS FIRED, BH NO. 2

Process Type: 13.310 (Natural Gas (includes propane and liquefied petroleum gas))

Primary Fuel: NATURAL GAS

Throughput: 76.00 MMBTU/H

Process Notes: LOCATED IN BOILER HOUSE #2

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102

Test Method: Unspecified

Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) 

Emission Limit 1: 6.0800 LB/H TOTAL

Emission Limit 2: 

Standard Emission: 0.0400 LB/MMBTU 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (P) LOW NOX BURNERS

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

CONTINUOUS COLD REDUCTION MILLS (5)

Process Type: 81.290 (Other Steel Manufacturing Processes)

Primary Fuel:

Previous Page

Attachment 2
Primary Fuel:

Throughput: 660.00 T/H (TOTAL)

Process Notes: VE SHALL NOT EXCEED AN AVERAGE OF 5% OPACITY IN 24 CONSECUTIVE READINGS; CERTIFIED VE READER SHALL

RECORD VISIBLE EMISSIONS ONCE PER WORKING SHIFT (DURING DAYLIGHT HOURS) FOR 12 MIN. DURING EACH

OBSERVATION

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VE

Test Method: Unspecified

Pollutant Group(s):

Emission Limit 1: 5.0000 % OPACITY 

Emission Limit 2: 

Standard Emission: 5.0000 % OPACITY 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (B) FIVE-STRAND CONTINUOUS COLD REDUCTION MILL SHALL BE ENCLOSED AND

MAINTAINED UNDER NEGATIVE PRESSURE; CONTROLLED BY MIST ELIMINATOR SYSTEM

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 16.1000 LB/H 

Emission Limit 2: 

Standard Emission: 0.0087 GR/DSCF 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (B) FIVE-STRAND CONTINUOUS COLD REDUCTION MILL SHALL BE ENCLOSED AND

MAINTAINED UNDER NEGATIVE PRESSURE; CONTROLLED BY MIST ELIMINATOR SYSTEM

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

TEMPER MILL

Process Type: 81.290 (Other Steel Manufacturing Processes)

Primary Fuel:

Throughput: 300.00 T/H

Process Notes: VE SHALL NOT EXCEED AN AVERAGE OF 5% OPACITY IN 24 CONSECUTIVE READINGS; A CERTIFIED VE READER

SHALL CONDUCT AND RECORD OBSERVATIONS ONCE PER WORKING SHIFT (DURING DAYLIGHT HOURS) FOR 12 MIN.

DURING EACH OBSERVATION PERIOD

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 5.7100 LB/H 

Emission Limit 2: 

Standard Emission: 0.0100 GR/DSCF 

Attachment 2
Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (A) MIST ELIMINATOR SYSTEM

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VE

Test Method: Unspecified

Pollutant Group(s):

Emission Limit 1: 5.0000 % OPACITY 

Emission Limit 2: 

Standard Emission: 5.0000 % OPACITY 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (A) MIST ELIMINATOR SYSTEM

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

APL STRETCH LEVELLER

Process Type: 81.600 (Pickling Processes)

Primary Fuel:

Throughput: 130.00 T/H

Process Notes: CONTINUOUS ANNEALING AND PICKLING LINE

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 0.0100 GR/DSCF 

Emission Limit 2: 1.8900 LB/H 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (A) FABRIC FILTER

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

APL ALKALINE CLEANER

Process Type: 81.600 (Pickling Processes)

Primary Fuel:

Attachment 2
Throughput:

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 0.0044 GR/DSCF 

Emission Limit 2: 0.3770 LB/H 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (A) WET SCRUBBER

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

ANNEALING FURNACE, SECTION NO. 1

Process Type: 13.310 (Natural Gas (includes propane and liquefied petroleum gas))

Primary Fuel: NATURAL GAS

Throughput: 72.30 MMBTU/H

Process Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102

Test Method: Unspecified

Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) 

Emission Limit 1: 1.8900 LB/H 

Emission Limit 2: 

Standard Emission: 0.0400 LB/MMBTU 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (P) LOW NOX BURNER

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

ANNEALING FURNACE, SECTION NO. 2

Process Type: 13.310 (Natural Gas (includes propane and liquefied petroleum gas))

Primary Fuel: NATURAL GAS

Throughput: 55.20 MMBTU/H

Process Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102

Test Method: Unspecified

Attachment 2
Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) 

Emission Limit 1: 2.2100 LB/H 

Emission Limit 2: 

Standard Emission: 0.0400 LB/MMBTU 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (P) LOW NOX BURNER

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

ANNEALING FURNACE, SECTION NO. 3

Process Type: 13.310 (Natural Gas (includes propane and liquefied petroleum gas))

Primary Fuel: NATURAL GAS

Throughput: 65.70 MMBTU/H

Process Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102

Test Method: Unspecified

Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) 

Emission Limit 1: 2.6300 LB/H 

Emission Limit 2: 

Standard Emission: 0.0400 LB/MMBTU 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (P) LOW NOX BURNER

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

APL AIR QUENCH SYSTEMS (6)

Process Type: 81.600 (Pickling Processes)

Primary Fuel:

Throughput: 130.00 T/H

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 0.0050 GR/DSCF 

Emission Limit 2: 10.2100 LB/H 

Standard Emission: NOT AVAILABLE

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Attachment 2
Other Applicable

Requirements:

Control Method: (P) ULTRA LOW NOX BURNERS WITH INTEGRAL EXHAUST GAS RECIRCULATION (OR

EQUIVALENT)

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

SHOT BLASTER CHAMBER

Process Type: 99.001 (Abrasive Blasting)

Primary Fuel:

Throughput: 130.00 T/H

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 0.0060 LB/H 

Emission Limit 2: 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (B) FABRIC FILTER; SHOT BLAST CHAMBER TO BE ENCLOSED AND MAINTAINED UNDER

NEGATIVE PRESSURE

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

ELECTROLYTIC PICKLING

Process Type: 81.600 (Pickling Processes)

Primary Fuel:

Throughput: 130.00 T/H

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 0.3490 LB/H 

Emission Limit 2: 

Standard Emission: 0.0022 GR/DSCF 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (A) WET SCRUBBER

Est. % Efficiency:

Compliance Verified: Unknown

Attachment 2
Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

MIXED ACID PICKLE AND RINSE TANKS

Process Type: 81.600 (Pickling Processes)

Primary Fuel:

Throughput:

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 0.0030 GR/DSCF 

Emission Limit 2: 0.1530 LB/H 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (B) ENCLOSE AND MAINTAIN UNDER NEGATIVE PRESSURE, WET SCRUBBER

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102

Test Method: Unspecified

Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) 

Emission Limit 1: 175.0000 PPMVD 

Emission Limit 2: 6.1800 LB/H 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (B) WET SCRUBBER, ENCLOSE AND MAINTAIN UNDER NEGATIVE PRESSURE

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

SKIN PASS TEMPER MILL, APL

Process Type: 81.600 (Pickling Processes)

Primary Fuel:

Throughput: 130.00 T/H

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Attachment 2
Emission Limit 1: 0.0066 GR/DSCF 

Emission Limit 2: 0.4590 LB/H 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (A) FABRIC FILTER

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

CPL STRIP LEVELER/MECHANICAL SCALE BREAKER

Process Type: 81.600 (Pickling Processes)

Primary Fuel:

Throughput: 476.00 T/H

Process Notes: CONTINUOUS PICKLING LINE

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 0.0044 GR/DSCF 

Emission Limit 2: 1.5200 LB/H 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (A) FABRIC FILTER

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

HCL PICKLING BATHS/RINSE TANKS

Process Type: 81.600 (Pickling Processes)

Primary Fuel:

Throughput: 476.00 T/H

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 0.0020 GR/DSCF 

Emission Limit 2: 0.2060 LB/H 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Attachment 2
Other Applicable

Requirements:

Control Method: (B) WET SCRUBBER; ENCLOSED AND MAINTAINED UNDER NEGATIVE PRESSURE

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

ELECTROSTATIC OILER

Process Type: 81.290 (Other Steel Manufacturing Processes)

Primary Fuel:

Throughput: 476.00 T/H

Process Notes:

POLLUTANT NAME: Volatile Organic Compounds (VOC)

CAS Number: VOC

Test Method: Unspecified

Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) 

Emission Limit 1: 3.3000 LB/GAL OIL 

Emission Limit 2: 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (P) ELECTROSTATIC APPLICATION ONLY; VOC CONTENT OF RUST PREVENTATIVE OIL

LIMITED TO 3.3 LB VOC/GAL OIL, EXCLUDING WATER AND EXEMPT SOLVENTS

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

CGL ALKALINE CLEANING BATHS/RINSE TANKS

Process Type: 81.290 (Other Steel Manufacturing Processes)

Primary Fuel:

Throughput:

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 0.1250 LB/H 

Emission Limit 2: 

Standard Emission: 0.0022 GR/DSCF 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (B) ENCLOSED AND MAINTAINED UNDER NEGATIVE PRESSURE; WET SCRUBBER

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Attachment 2
Process/Pollutant Information

PROCESS

NAME:

DRYER, CGL CLEANING SECTION

Process Type: 81.290 (Other Steel Manufacturing Processes)

Primary Fuel: NATURAL GAS

Throughput: 4.10 MMBTU/H

Process Notes: CONTINUOUS GALVANIZING LINE (CGL)

POLLUTANT NAME: Sulfur Oxides (SOx)

CAS Number: 7446

Test Method: Unspecified

Pollutant Group(s): ( InOrganic Compounds , Oxides of Sulfur (SOx) ) 

Emission Limit 1: SEE METHOD DESCRIPTION

Emission Limit 2: 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: Other Case-by-Case

Other Applicable

Requirements:

Control Method: (P) INDIANA HAS RESTRICTED FACILITY TO BURNING NATURAL GAS ONLY. NO

EMISSION LIMIT SET FOR SOX.

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

FURNACE, INDUCTION AND HEATING GALVANNEALING

Process Type: 12.310 (Natural Gas (includes propane and liquefied petroleum gas))

Primary Fuel: NATURAL GAS

Throughput: 205.70 MMBTU/H

Process Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102

Test Method: Unspecified

Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) 

Emission Limit 1: 12.3000 LB/H 

Emission Limit 2: 

Standard Emission: 0.0600 LB/MMBTU 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (A) SELECTIVE CATALYTIC REDUCTION (SCR)

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

CGL CHROMATING SECTION

Attachment 2
Process Type: 81.290 (Other Steel Manufacturing Processes)

Primary Fuel:

Throughput: 183.60 T/H

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 0.0370 LB/H 

Emission Limit 2: 

Standard Emission: 0.0009 GR/DSCF 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (A) WET SCRUBBER

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

HYDROGEN BATCH ANNEALING FURNACES (16)

Process Type: 13.310 (Natural Gas (includes propane and liquefied petroleum gas))

Primary Fuel: NATURAL GAS

Throughput: 6.75 MMBTU/H

Process Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102

Test Method: Unspecified

Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) 

Emission Limit 1: 9.4500 LB/H 

Emission Limit 2: 

Standard Emission: 0.1000 LB/MMBTU 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (P) LOW NOX BURNERS

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

DIP TANK, ELECTROLYTIC CHROME

Process Type: 99.007 (Hard Chromium Electroplating)

Primary Fuel:

Throughput:

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

Attachment 2
POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: GR/DSCF SEE POLLUTANT NOTES

Emission Limit 2: 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: N/A

Other Applicable

Requirements:

NESHAP 

Control Method: (A) WET SCRUBBER

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes: PM IS LIMITED TO 0.0000066 GR/DSCF ACCORDING TO NESHAP SUBPART N.

POLLUTANT NAME: Chromium Compounds, -3 only

CAS Number: 7440-47-3

Test Method: Unspecified

Pollutant Group(s): ( Hazardous Air Pollutants (HAP) , InOrganic Compounds , Particulate Matter (PM) ) 

Emission Limit 1: 0.0150 MG/DSCM 

Emission Limit 2: 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: Other Case-by-Case

Other Applicable

Requirements:

Control Method: (A) WET SCRUBBER

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

ELECTRODISCHARGE TEXTURING MACHINES

Process Type: 81.290 (Other Steel Manufacturing Processes)

Primary Fuel:

Throughput:

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 0.0120 LB/H 

Emission Limit 2: 

Standard Emission: 0.0020 GR/DSCF 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (A) FABRIC FILTER

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Attachment 2
Process/Pollutant Information

PROCESS

NAME:

BOILERS (3), NATURAL GAS FIRED, BH NO. 1

Process Type: 13.310 (Natural Gas (includes propane and liquefied petroleum gas))

Primary Fuel: NATURAL GAS

Throughput: 76.00 MMBTU/H

Process Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102

Test Method: Unspecified

Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) 

Emission Limit 1: 9.1200 LB/H TOTAL

Emission Limit 2: 

Standard Emission: 0.0400 LB/MMBTU 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (P) LOW NOX BURNERS

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

COOLING TOWERS (2), NON-CONTACT

Process Type: 99.009 (Industrial Process Cooling Towers)

Primary Fuel:

Throughput:

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 0.0050 % DRIFT 

Emission Limit 2: 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (A) DRIFT ELIMINATORS

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Facility Information

Previous Page

Attachment 2
RBLC ID: CA-0650 (final) Date Determination

Last Updated: 12/18/2001

Corporate/Company Name: KING INDUSTRIAL HARD CHROME Permit Number: A/C NO. C-2494-1-0

Facility Name: KING INDUSTRIAL HARD CHROME Permit Date: 06/30/1995 (actual)

Facility Contact: FRS Number: 110017401863

Facility Description: SIC Code: 3471

Permit Type: A: New/Greenfield Facility NAICS Code:

Permit URL:

EPA Region: 9 COUNTRY: USA

Facility County: FRESNO

Facility State: CA

Facility ZIP Code:

Permit Issued By: SAN JOAQUIN VALLEY APCD - CENTRAL REGIONAL OFFICE, CA (Agency Name) 

MR. GEORGE HEINEN(Agency Contact) (559) 230-6000 

Other Agency Contact Info: SEYED SADREDIN 

CA

(209) 468-3474

Permit Notes:

Process/Pollutant Information

PROCESS

NAME:

HARD CHROME PLATING OPERATION

Process Type: 99.007 (Hard Chromium Electroplating)

Primary Fuel:

Throughput: 5.00 MM AMP-HR/YR

Process Notes: COMPLIANCE TO BE VERIFIED BY SOURCE TEST

POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)

CAS Number: PM

Test Method: Unspecified

Pollutant Group(s): ( Particulate Matter (PM) ) 

Emission Limit 1: 0.0700 MG/AMP-HR 

Emission Limit 2: 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: Other Case-by-Case

Other Applicable

Requirements:

Control Method: (B) MERLIN SEALED AND ENCLOSED TANKS COVERED WITH 0.1 MICRON TEFLON VENT

FILTER

Est. % Efficiency: 99.000

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Previous Page

Attachment 2
COMPREHENSIVE REPORT

Report Date:05/27/2010

Facility Information

RBLC ID: OH-0219 (final) Date Determination

Last Updated: 10/09/2002

Corporate/Company Name: SUPREME BUMPER, INC. Permit Number: 04-832

Facility Name: SUPREME BUMPER, INC. Permit Date: 07/09/1993 (actual)

Facility Contact: FRS Number: 110000383969

Facility Description: SIC Code: 3471

Permit Type: A: New/Greenfield Facility NAICS Code: 332813

Permit URL:

EPA Region: 5 COUNTRY: USA

Facility County:

Facility State: OH

Facility ZIP Code:

Permit Issued By: CITY OF TOLEDO, ENV SERVICES DIV, OH (Agency Name) 

MS. KAREN GRANATA(Agency Contact) (419)936-3952 karen.granata@ci.toledo.oh.us 

Other Agency Contact Info: BOB KOSSOW 

OH

(419) 697-5104

Permit Notes: 1. Emission Limits Set as Tlv at the Stack Discharge with Modeling of Ground Level Concentrations < Tlv-42.

Process/Pollutant Information

PROCESS

NAME:

EVAPORATOR

Process Type: 99.005 (Decorative Chromium Electroplating)

Primary Fuel:

Throughput: 160.00 LB H20/H

Process Notes:

POLLUTANT NAME: Chromium / Chromium Compounds, -3 & -6

CAS Number: 7440-47-3

Test Method: Unspecified

Pollutant Group(s): ( Hazardous Air Pollutants (HAP) , Heavy Metals , InOrganic Compounds , Particulate Matter (PM) ) 

Emission Limit 1: 0.0005 LB/H 

Emission Limit 2: 0.0500 MG/M(3) 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: Other Case-by-Case

Other Applicable

Requirements:

Control Method: (A) CHEVRON ELIMINATORS, WET SCRUBBER, & MIST PAD

Est. % Efficiency: 99.000

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Facility Information

Previous Page

Previous Page

Attachment 3
RBLC ID: VA-0193 (final) Date Determination

Last Updated: 10/03/2002

Corporate/Company Name: HOECHST CELANESE CORPORATION Permit Number: 20304

Facility Name: HOECHST CELANESE CORPORATION Permit Date: 02/25/1993 (actual)

Facility Contact: DOUGLAS FEUERBACH FRS Number: 110000343147

Facility Description: SIC Code: 2823

Permit Type: A: New/Greenfield Facility NAICS Code: 325221

Permit URL:

EPA Region: 3 COUNTRY: USA

Facility County: GILES

Facility State: VA

Facility ZIP Code: 24124-

Permit Issued By: VIRGINIA ENVIRONMENTAL QUALITY AIR DIV. (Agency Name) 

MS. MONICA A. HARVEY(Agency Contact) (804)698-4300 MAHARVEY@DEQ.VIRGINIA.GOV 

Other Agency Contact Info: STEVE DIETRICH 

VA

(540) 562-6762

Permit Notes: 1. TESTING WAS REQUIRED. 2. THROUGHPUT CAPACITY OF CIGARETTE TOW PRODUCTION FACILITY WAS

DECLARED CONFIDENTIAL. 3. IN ADDITION TO THE CARBON ADSORPTION UNITS, THE PLANT HAS

INSTALLED SEVERAL ADDITIONAL INNOVATIVE CONTROLS TO REDUCE THE AMOUNT OF ACETONE

EMISSIONS. THE RESULT IS AN EXPANSION IN CAPACITY WITHOUT AN INCREASE IN EMISSIONS. 4. CAPACITY

AND EMISSION LIMIT FOR CHROME PLATING OPERATION LISTED AS "NA". 5. DETERMINATION FOR A

CIGARETTE TOW PRODUCTION FACILITY. 6. PORTIONS OF FACILITY STARTED UP IN MARCH 1989.

Process/Pollutant Information

PROCESS

NAME:

CIGARETTE TOW PRODUCTION FACILITY

Process Type: 65.999 (Other Synthetic Fibers Production Sources)

Primary Fuel:

Throughput: 0 

Process Notes:

POLLUTANT NAME: Acetone

CAS Number: 67-64-1

Test Method: Unspecified

Pollutant Group(s):

Emission Limit 1: 5204.0000 T/YR 

Emission Limit 2: 433.7000 T/MO 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (A) CARBON ADSORPTION

Est. % Efficiency: 98.900

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS

NAME:

PLATING, CHROME

Process Type: 99.005 (Decorative Chromium Electroplating)

Primary Fuel:

Throughput:

Process Notes: PROCESS (CHROME PLATING) IS USED IN CONFUNCTION WITH THE PRODUCTION OF SYNTHETIC FIBER FOR

Attachment 3
Process Notes: PROCESS (CHROME PLATING) IS USED IN CONFUNCTION WITH THE PRODUCTION OF SYNTHETIC FIBER FOR

CIGARETTE TOW.

POLLUTANT NAME: Chromium Compounds, -6 only

CAS Number: 7440-47-3

Test Method: Unspecified

Pollutant Group(s): ( Hazardous Air Pollutants (HAP) , InOrganic Compounds , Particulate Matter (PM) ) 

Emission Limit 1: NOT AVAILABLE

Emission Limit 2: 

Standard Emission: 

Did factors, other then air pollution technology considerations influence the BACT decisions:

 

Unknown

Case-by-Case Basis: BACT-PSD

Other Applicable

Requirements:

Control Method: (P) DECREASED SURFACE AREA OF PLATING BATH

Est. % Efficiency: 70.000

Compliance Verified: Unknown

Pollutant/Compliance Notes:

Previous Page

Attachment 3
Chrome Plating and Anodizing Operations 

Cal/EPA – January 2006 1 

306 EMISSIONS CONTROL 

TECHNIQUES

 

TABLE OF CONTENTS

306 EMISSIONS CONTROL TECHNIQUES

 306.1 FUME SUPPRESSANTS 

 306.1.1 Chemical Fume Suppressants

 306.1.2 Mechanical Fume Suppressants

 306.2 ADD-ON CONTROL DEVICES

 306.2.1 Capture Techniques

 306.2.2 Pack-Bed Scrubbers

 306.2.3 Mist Eliminators 

 306.2.4 HEPA Filters 

 306.2.5 Combination Systems

 306.2.6 Encapsulating Tank Covers

 

 

 

306 EMISSIONS CONTROL TECHNIQUES

To comply with the State ATCM regulation, a plating or anodizing facility must either

1. Meet a surface tension limit using chemical fume suppressants containing a wetting agent or; 

2. Meet an emission limit (mg/amp-hr or mg/dscm) demonstrated by a performance test. 

Techniques to control hexavalent chromium emissions from chrome electroplating and anodizing 

tanks include fume suppressants and add-on control devices. In the first, an anti-mist additive is 

added to the plating bath to reduce the amount of misting that takes place. In the second, the mist is 

captured, and the entrained chromium is extracted from the exhaust air stream prior to discharge to 

the stack. 

In California, decorative platers typically use an anti-mist additive to achieve compliance with the 

State's hexavalent chromium emissions limit. About 25% of decorative platers in the State uses addon control equipment in addition to an anti-mist additive. About 5% use only add-on control equipment 

to reduce hexavalent chromium emissions.

Hard chrome platers in California use add-on controls to achieve compliance with the State's 

hexavalent chromium emissions limit. However, about 50% of hard chrome platers in the State use an 

anti-mist additive in conjunction with add-on controls to reduce hexavalent chromium emissions from 

their tanks. 

Attachment 4
Chrome Plating and Anodizing Operations 

Cal/EPA – January 2006 2 

About 40% of chromic acid anodizing operations in the State use an anti-mist additive alone to 

achieve compliance. Another 40% use an anti-mist additive in conjunction with add-on controls. The 

remaining 20% use only add-on controls to reduce hexavalent chromium emissions from their tanks.6

306.1 FUME SUPPRESSANTS

Fume suppressants are mist suppressant or physical barriers at the surface of the plating bath used 

to control chromic acid mists. There are two categories of fume suppressants: chemical fume 

suppressant and mechanical fume suppressant. 

306.1.1 Chemical Fume Suppressant

A chemical fume suppressant is any chemical agent that reduces or suppresses fumes or mists at the 

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

suppressant. Fume suppressants can be temporary or permanent depending on the mechanism of 

depletion from the baths. Temporary fume suppressants are depleted mainly by the decomposition of 

the active chemical components. Permanent fume suppressants are depleted by drag-out of the 

solution. 

Chemical fume suppressants are added directly to the bath to reduce or inhibit misting. Chemical 

fume suppressants include: wetting agents, foam blankets (Figure 306-1), and combinations of both 

(Figure 306-2). Most chemical fume suppressants in use today contain wetting agents. The difference 

between wetting agents and foam blankets is the way in which they reduce emissions. Wetting agents 

control misting by lowering the surface tension of the bath, while foam blankets physically suppress 

the mists produced on the surface of the bath.

Fume suppressants are manufactured in liquid, powder, or tablet form. Some of the main advantages 

of using chemical fume suppressants include:

 1. Minimization of plating solution evaporation losses; 

 2. Low cost of chromium emission control; 

 3. Very little energy consumption; and 

 4. No solid waste generation.

Limitations in using chemical fume suppressants include:

 1. Some fume suppressants have a tendency to aggravate gas pitting and defects in base metals; 

 and 

 2. Foam blankets that are too thick can entrap hydrogen gas, which poses a risk of explosion.

Chemical fume suppressants typically reduce chromium emissions between 93 and 99 percent.1

306.1.1A Foam Blankets

A foam blanket is a type of chemical fume suppressant that generates a layer of foam across the 

surface of a solution when current is applied to that solution. Foam blankets do not prevent the 

formation of chromic acid mist, but instead trap the mist under a blanket of foam. The foam blanket is 

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Cal/EPA – January 2006 3 

formed by the agitation produced by hydrogen and oxygen gas bubbles generated during 

electroplating. Once formed, the foam blanket is usually maintained at a thickness of 1.3 to 2.5 

centimeters (0.5 to 1.0 inches) and covers the entire surface of the plating bath (see Figure 306-1). 

The ability of the foam layer to contain mist is greatly reduced if proper thickness is not maintained. If 

the foam blanket is too thin, less than 1.3 centimeters (0.5 inches), it will no longer trap the chromium 

containing mist. Conversely, a thickness greater than 2.5 centimeters (1.0 inches) will cause 

hydrogen gas to build up in the foam layer, creating a hydrogen explosion hazard should a spark be 

generated from the contacting equipment. These problems tend to occur more frequently with higher 

current densities and longer plating times.1

Figure 306-1. Foam Blanket

The characteristics of foam blanket solutions are determined by the surface area of the solution, 

amount of current applied, and temperature and chromic acid concentration of the plating bath, (e.g. 

less suppressant is required at lower temperatures). Visual monitoring of the thickness of the foam 

blanket is the most common method for determining when to add foam blanket solution to the bath. 

The frequency of adding foam blanket solution, also, depends upon the drag-out rate of the solution 

and the amount of work being performed in the plating tank. Chemical decomposition, to a greater 

extent than drag-out, is the primary mechanism for depletion of foam blankets.

306.1.1B Wetting Agents

A wetting agent is a type of chemical fume suppressant that reduces the surface tension of a liquid. 

When wetting agents lower the surface tension of a plating bath, gases escape at the surface of the 

solution with less of a "bursting" effect, causing less mist formation. In essence, a wetting agent 

reduces bubble size, and smaller bubbles burst with less impact on the surface.

Plating bath typically have a surface tension of 70 dynes/cm. With the addition of sufficient wetting 

agent, the surface tension of the plating bath can be reduced to 45 dynes/cm or less where it has 

been shown to create a rapid reduction in chromic acid emissions.1

 The two methods used to 

measure the surface tension of the plating solution are the stalagmometer (the drop weight method) 

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Cal/EPA – January 2006 4 

and the tensiometer (the ring method). Most plating facilities use a stalagmometer to measure the 

surface tension. Go to the Photo Gallery to view pictures of the stalagmometer and the tensiometer.

Figure 306-2. Fume Suppressant - Combination of Wetting Agent and Foam

306.1.2 Mechanical Fume Suppressant

A mechanical fume suppressant is any device that reduces fumes or mist at the surfaces of an 

electroplating or anodizing bath by direct contact with the surface of the bath. Polyballs (Figure 306-3) 

are the most commonly used mechanical fume suppressant. Polyballs are hollow, plastic floating 

spheres with typical sizes range from 3/4 to 2 inches in diameter. They are fabricated from plastics 

that are resistant to chemical attack and are used to reduce heat loss, bath evaporation, and misting. 

In order to be most effective, balls must cover the entire surface area of the bath. 

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Figure 306-3. Polyballs 

The U.S. EPA has examined the use of these floating spheres for air pollution control purposes, and 

found them to be of limited use. In one such test, a two to three inch layer of 1.5 inches in diameter 

spheres achieves a removal efficiency of only about 75 percent.1

 The effectiveness of polyballs is also 

reduced by the fact that the evolution of hydrogen gas at the workpiece tends to push the spheres 

away, exposing a portion of the plating bath surface to the air above.

 

306.2 CONTROL DEVICES

This section discusses the capture techniques to capture the chromium misting at the surface of the 

tank and the add-on control devices available to extract the entrained chromium from the exhaust air 

stream prior to discharge to the stack. An add-on air pollution control device is any equipment 

installed in the ventilation system of chrome electroplating and anodizing tanks for the purposes of 

collecting and holding chromium emissions from the tank(s). Add-on control devices include: packbed scrubbers, mesh pad mist eliminators, fiber bed mist eliminators, and combination systems. Also 

discussed is the encapsulating tank cover which does not require an exhaust stack to vent process air 

outside of the facility.

306.2.1 Capture Techniques - Lateral Exhaust System

Local exhaust ventilation is the most common method used to capture chromic acid mist from chrome 

plating and chromic acid anodizing baths. Typical local exhaust ventilation equipment includes lateral 

(slot) and push-pull exhaust hoods. Canopy hoods or overhead exhaust hoods and enclosures are 

normally not used because they restrict access to the plating or anodizing tank. In addition, overhead 

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Cal/EPA – January 2006 6 

hoods would draw mists from the tank surface into the breathing zone of anyone who was working at 

the tank. However, there is a control system called the encapsulating tank lid or cover used by hard 

chrome platers that contains the mist while allowing other gasses to vent. This control system is 

further discussed in Subsection 306.2.6, Encapsulating Tank Covers.

A tank is said to be "laterally exhausted" if the hood does not project over the entire tank and the 

direction of the air movement into the hood is substantially horizontal. Lateral exhaust systems 

typically used to control chromic acid mist from open-surface tanks include both single-sided and 

double-sided slot hoods. The slot velocity affects the uniformity of airflow distribution along the length 

of the hood. 

Single-sided hoods have a maximum reach across the width of the tank of about 30 inches (2 and 1/2 

feet) while double-sided hoods have a maximum reach of about 60 inches (5 feet). In this system, the 

chromic acid mists are collected by slot vents which usually run along the long side (single-sided) or 

along both long sides of the tank (double-sided) (see Figure 306-4). 

Figure 306-4. Slot Vents on a Lateral Exhaust System

Push-pull ventilation is recommended for tanks greater than 42 inches (3 and 1/2 feet) in width. In a 

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push-pull system (Figure 306-5), one slot vent is an intake ("pull") while the other supplies air under 

pressure ("push"). Push air supplied through slots, orifices, or nozzles is blown across the width of the 

tank to direct contaminated air toward the exhaust hood, the "pull" vent, located on the opposite side 

of the tank. 

Figure 306-5. Push-Pull System 

306.2.2 Packed Bed Scrubbers

A packed-bed scrubber (PBS) consists of a single or double packed bed that contains packing media 

on which the chromic acid droplets attach. First, the gas stream is wetted by spraying water against 

the flow of the gas to make the droplets larger. Then the gas stream passes through the packed 

bed(s) where the droplets attach onto the packing media. A mist eliminator section follows the packed 

bed section of the scrubber. The mist eliminator removes any water entrained from the packed bed 

section. Treated gases then pass through an induced draft fan and out a stack of exhaust vent. The 

scrubber water is recirculated and periodically tapped and discharged to the electroplating tanks as 

makeup solution. Figure 306-6 shows a packed-bed scrubber. 

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A PBS has a typical efficiency of 97 percent for decorative chromium electroplating and anodizing 

tanks and 99% for hard chromium electroplating tanks. Factors influencing efficiency include: liquidto-gas ratio (the flooding or starving of the media with scrubbing liquor), gas velocity, surface area 

and type of packing media, distribution of the media in the bed, and effectiveness of washdown 

procedures.3

 

Figure 306-6. Packed-Bed Scrubber 

(Courtesy of Midwest Air Products Co., Inc. (MAPCO), adapted)

306.2.3 Mist eliminators

Mist eliminators generally remove droplets from gas streams by inertial impaction of droplets on these 

devices and centrifugal force applied to the gas stream. Many types of mist eliminating devices have 

been developed, but most are categorized within the following types: chevrons, mesh pads, and fiber 

beds. 

Mist eliminators may be used in a horizontal or vertical gas flow configuration. When mist eliminators 

are used on a vertical gas stream, liquids removed from the gas will drip from the eliminator from the 

force of gravity on the liquid against the flow of the gas stream. Liquids collected by mist eliminators 

used on horizontal gas flows will not drip against the flow of the gas, so horizontal mist eliminators 

can handle higher gas velocities and liquid loadings.

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Mist eliminators are usually equipped with liquid sprays to prevent the accumulation of solids. An 

accumulation of solids can plug part of the eliminator, reduce the area of flow, create excessive 

pressure drops and increase liquid entrainment. Properly operating mist eliminators usually have a 

pressure drop between 0.5 and 4.0 inches of water. Type, size, and composition of the pads are 

dependent on the system they are incorporated in (i.e. gas density, flow velocity, etc.).

306.2.3A Chevron-Blade Mist Eliminators

Chevrons are devices composed of zigzag baffles which force a gas stream to turn sharply. Liquids 

collect on the blades of the chevron and drain downward by gravity. Basically, a series of parallel 

zigzag blades (see Figure 306-7) are positioned in the body or housing of the device, in order to direct 

the air flow through narrow passageways that repeatedly change its direction by approximately 30 

degrees. At regular intervals, the extruded blades have narrow vertical channels which serve to 

capture some of the chromium droplets by inertial forces. Since the channels are oriented in a vertical 

plane, condensed chrome is transported to a drain at the bottom of the housing. Common blade 

designs are the overlapping and sinusoidal wave designs (see Figure 306-7). 

Figure 306-7 Blade Configurations Used in Chevron Mist Eliminators 

(EPA Capsule Report) 

Blade-type horizontal mist eliminators have demonstrated a wide efficiency range. Removal 

efficiencies ranged from about 83 to 99 percent. Some of the factors influencing efficiency were: gas 

velocity, blade spacing, seal integrity, and wash down frequency.1, 3 

306.2.3B Composite Mesh Pad Mist Eliminators

A composite mesh pad mist eliminator (CMP) consists of several layers of interlocked fibers densely 

packed between two supporting grids. The composite mesh pad was developed to remove small 

particles (< 5 micrometers or 0.2 mils) that were not effectively controlled by other control devices. 

There are usually at least three mesh pad stages (see Figure 306-8). The first stage removes large 

particles. The second stage removes smaller particles using a composite mesh pad. The final stage 

may remove any reentrained particles not collected by the composite mesh pad in the second stage. 

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A reentrained particle is a particle which was caught by the mesh pad, but some force removed it 

from the mesh pad and returned it to the air stream.

The layers of material in composite pads are arranged with the smallest diameter fiber layer located in 

the center of the pad and progressively larger diameter layers located on both sides of the center. 

Particles collide with the fibers in the pad and attach to the fiber surfaces. These captured particles 

combine into larger particles as they travel through the small diameter fiber layers in the center of the 

pad. These larger particles either drain to the bottom of the unit or are reentrained in the gas stream. 

The reentrained particles are then captured by the large diameter fiber layers in the back of the pad.

CMP systems incorporate a larger particle removal system located upstream from the composite 

mesh pad, to reduce the plugging potential of the pad. The large particle removal system can either 

be a series of larger diameter mesh pads or a packed bed scrubber section. Typical removal 

efficiencies associated with this control device are greater than 99 percent.1, 3 

 

 

 

Figure 306-8. Mesh Pad Mist Eliminator 

(Courtesy of Midwest Air Products Co., Inc. (MAPCO), adapted) 

 

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306.2.3C Fiber Bed Mist Eliminators

A fiber bed mist eliminator (FBME) removes contaminants from a gas stream through the 

mechanisms of inertial impaction and Brownian diffusion. FBMEs have most often been used to 

reduce acid mists from sulfuric, phosphoric, and nitric acid plants. An FBME consists of one or more 

fiber beds. Each bed consists of a hollow cylinder formed from two concentric screens (see Figure 

306-9). The fiber between the screens may be made of glass, ceramic, plastic, or metal. Fiber bed 

units are designed for horizontal, concurrent gas liquid flow through the fiber bed. The contaminated 

gas stream flows toward the downstream face of the bed. The acid mist in the gas stream impacts on 

the surface of the fibers and drains down the outer face of the bed to the sump while the clean gas 

flows up and out the top of the unit.

Figure 306-9 Fiber Bed Mist Eliminator 

(EPA Capsule Report) 

 

A FBME device is typically installed downstream from another control device that can prevent 

plugging of the FBME device. The upstream device removes the majority of the emissions and thus 

prevents plugging of the fiber bed.

To date, there is no adequate test data available to accurately quantify the control efficiency of FBME. 

The U.S. EPA believes that these systems can achieve the same emission limits as CMP systems 

and chemical fume suppressants.1, 3

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306.2.4 HEPA Filters

A High Efficiency Particle Arresting or Particulate Air (HEPA) filter is defined by the Department of 

Energy (DOE) as a throwaway, extended-media, dry type filter with a rigid casing enclosing the full 

length depth of the pleats. The filter shall exhibit a minimum efficiency of 99.97% when tested at an 

aerosol of 0.3 micrometers diameter.5

 These filters were originally designed to trap microscopic 

particles such as radioactive dust in atomic plants and are commonly used for critical environments 

like hospitals, clean rooms, and lead abatement projects. Figure 306-9 illustrates a HEPA filter 

system.

Figure 306-9. HEPA Filter System

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306.2.5 Combination Systems

Combination systems are various arrangements of multiple control devices, as discussed above, in a 

common exhaust system. Some of the variations include:

1. Mesh pads installed in exhaust hoods at the tank, followed by an end-of-line mesh pad or 

packed bed scrubber;

2. In-line mesh pad mist eliminators, located after the exhaust hoods, followed by an end-ofline mesh pad or packed bed scrubber;

3. Blade-type horizontal mist eliminators followed by an end-of-line mesh pad or packed bed 

scrubber;

4. Mesh pad mist eliminator system followed by a high efficiency particulate air (HEPA) filter 

as a final polishing device; and

5. Mesh pad mist eliminator system followed by a filter bed as a final polishing device.

Some of the advantages in using multiple devices include: segregating chemicals, keeping duct work 

clean, and reducing the inlet loading on the end-of-line unit.1

 

306.2.6 Encapsulating Tank Covers

An encapsulating tank cover involves the use of a special tank hood or cover that contains the mist 

while allowing other gasses to vent (see Figure 306-10). The system does not require an exhaust 

stack to vent process air outside of the facility. The hydrogen and oxygen gas, generated during the 

chrome plating process, pass through a selective membrane system to the plating room environment. 

Water vapor and chromic acid mist do not penetrate the membrane, but will condense within the 

confines of the tank's cover. At the end of the plating batch, an evacuation cycle removes latent 

fumes or mists prior to opening the cover for partial retrieval. This approach can reduce the building's 

energy requirements significantly, since the unit does not exhaust conditioned air outdoors, and there 

are no large fan motors. An additional benefit is that no chromium-bearing fluids are generated, as 

with the washdown cycles of mesh pad mist eliminator systems or the recirculated liquor in packedbed scrubbers.

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Figure 306-10. Encapsulating Tank Cover 

(EPA Capsule Report, PF Online) 

 

Because water vapor is not removed from the plating bath through surface evaporation, reclaim 

rinsing strategies and cooling systems may be adversely affected. Also, parts should either have 

identical start/stop times (i.e., batch plated) or be capable of multiple plating cycles, since all plating in 

the tank must be stopped before any parts can be added or removed.1, 4

 

 

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References

1.U.S. EPA, 1998, Capsule Report-Hard Chrome Fume Suppressants and Control Technologies, 

Office of Research and Development, Washington DC, Document No. EPA/625/R-98/002, 

December 1998, Available online at: 

http://www.epa.gov/ORD/NRMRL/pubs/625r98002/625r98002.pdf

2. U.S. EPA, 1993, Chromium Emissions from Chromium Electroplating and Chromic Acid Anodizing 

Operations-Background Information for Proposed Standards, Document No. 

EPA 453/R-93-030b, p. 4-1 - 4-70

3. Colorado Department of Public Health and Environment (CDPHE), 1999, CDPHE Chromium 

MACT - Control Measures, Last updated April 21, 1999, Accessed January 20, 2005, 

http://www.cdphe.state.co.us/ap/chromium/html/control/index.html 

4. PF Online an online component of Products Finishing magazine, 1997, Reducing Hexavalent 

Chromium Emissions, December 1997, Accessed on May 25, 2004, 

http://www.pfonline.com/articles/129705.html

5. U.S. Department of Energy, 1997, DOE Standard Specification for HEPA Filters Used By DOE 

Contractors, Document No.: DOE-STD-3020-97, Washington, D.C., January 1997, p. 4, Accessed on 

September 21, 2005, http://www.eh.doe.gov/hepa/docs/std3020.pdf

6. California Air Resources Board, telephone discussion with Shobna Sahni, Lead staff on ATCM for 

Chrome Plating and Chromic Acid Anodizing Operations, September 2005

7. California Air Resources Board, 2000, Toxics Enforcement Manual, Part B: NESHAP/MACT 

Guideline Documents, Volume 2, Chapter I, Chrome Electroplating and Anodizing Operations, 

Compliance Assistance Program, Sacramento, CA, November 2000, p. 200-12 - 200-18

Attachment 4