CHROME PLATING

RULE EFFECTIVENESS STUDY REPORT

Prepared by:

California Air Resources Board

Stationary Source Division

July 2002
State of California

California Environmental Protection Agency

Air Resources Board

Chrome Plating Rule Effectiveness Study

July 2002

Contributing Staff

Steve Eve

Supervision

Jorge Fernandez, Chief, Program Evaluation Branch

Hardip Judge, Manager, Program Review Section

The energy challenge facing California is real. Every Californian needs to take

immediate action to reduce energy consumption. For a list of simple ways you

can reduce demand and cut your energy costs, see our Website:

http://www.arb.ca.gov.
ACKNOWLEDGMENTS

This report was prepared by the Air Resources Board staff in cooperation with

representatives of South Coast AQMD, Bay Area AQMD, San Joaquin Valley Unified

APCD, Sacramento Metropolitan AQMD, and San Diego County APCD. Staff from

these air districts participated in the field inspections and provided helpful comments and

suggestions in developing the report content. We particularly wish to acknowledge the

valuable assistance of the following air district staff for their help in coordinating this

field study and reviewing this document:

David Jones South Coast AQMD

Sam Vergara South Coast AQMD

Jack Bean Bay Area AQMD

Nora Lew Bay Area AQMD

Bob Kard San Joaquin Valley Unified APCD

Clif Calderwood San Joaquin Valley Unified APCD

David Grose Sacramento Metropolitan AQMD

Kevin Leonard Sacramento Metropolitan AQMD

Teresa Morris San Diego County APCD

Gary Hartnett San Diego County APCD
1

Chrome Plating Rule Effectiveness Study

Introduction

A joint study of chrome plating facilities was conducted in five air districts in

California (Bay Area, Sacramento, San Diego, San Joaquin and South Coast) between

November 16, 1999 and November 9, 2000. ARB and district staff inspected 188 chrome

platers for compliance with the Chrome Plating Airborne Toxic Control Measure

(ATCM).

In order to evaluate the effectiveness of the ATCM and its implementation, this

report looks at non-compliance rates among the facilities and permit units inspected,

violations of the ATCM requirements, inspection frequency, inspector training,

enforcement actions, penalty settlement amounts, settlement times, parameter monitoring,

calibration requirements and permit quality. The report also makes recommendations for

improving compliance with the ATCM and summarizes several improvements

voluntarily made by the participating air districts.

As a separate effort, ARB staff is in the process of updating the ATCM to ensure

it continues to provide the most feasible public health protection. As part of the update

process, staff is evaluating new and existing technologies for pollution prevention, and

also evaluating control equipment that may further reduce emissions from hard and

decorative chrome plating and anodizing facilities. Another part of our evaluation is an

emission testing program focussed on better quantifying emissions from the decorative

chrome plating process. The results of all of these evaluations will aid in determining if

further control of hexavalent chromium emissions is needed. ARB’s current hexavalent

chromium activities can be seen at http://www.arb.ca.gov/toxics/chrome/chrome.htm.

What is a rule effectiveness study?

A rule effectiveness study is a thorough examination of a rule category and its

implementation. Rule effectiveness studies are field evaluation studies designed to

determine the percentage of non-compliance among sources within a selected rule

category. A representative number of sources within the study group are chosen at

random and inspected. The effectiveness of a rule is reflected in the non-compliance

rates determined by dividing the number of non-complying facilities and/or equipment by

the number inspected.

Why was this project initiated?

This project was done in order to examine how well chrome plating facilities were

performing with respect to their compliance with the existing Chrome Plating Airborne

Toxic Control Measure (ATCM) and the air districts’ chrome plating regulations. The

first ATCM on this subject was adopted by the ARB in 1988. This was amended in 1998

in order to improve the State’s control measure and make it as stringent as the Chrome

Electroplating Standard promulgated by the U.S. EPA in 1995. U.S. EPA granted
2

California the authority to implement and enforce its Chrome Plating ATCM

(equivalency) in place of the Chrome NESHAP on April 14, 1999. Local air districts are

required to implement and enforce the ATCM no later than 120 days after the effective

date of the ATCM or adopt an alternative regulation no later than six months after the

effective date of the ATCM.

Why Chrome Plating?

The potential hazard posed by emissions from chrome plating operations makes it

necessary to ensure their full compliance. Hexavalent chromium compounds are

regulated as toxic air contaminants in California under AB 1807 (1983) and federally as

hazardous air pollutants under the Clean Air Act Amendments of 1990. Hexavalent

chromium is a potent known carcinogen. This compound is emitted during chrome

plating and anodizing operations. Public exposure to hexavalent chromium can be

elevated in communities near plating facilities. Chrome plating operations are typically

small facilities often located in low-income areas. Thus, improved compliance rates will

reduce exposure in these low-income communities.

Project Preparation

ARB staff invited five California air districts (Bay Area, Sacramento, San Diego,

San Joaquin and South Coast) to participate in a rule effectiveness study on chrome

plating operations. Even though the study is limited to these five districts, the results

should indicate statewide trends because approximately 98% of the State’s chrome

plating operations are concentrated in these five districts. Representatives of ARB and

the five air districts met at the South Coast AQMD for a Chrome Plating Study Group

Meeting to finalize project plans. The study group decided to conduct joint inspections,

take enforcement action according to each District’s existing policy, collect chromic acid

samples to verify surface tension, share inspection results, and prepare a consensus

report.

Field Inspections

Inspections were conducted jointly by ARB and the five districts. Inspectors

conducted a walk-through inspection of each facility and reviewed records for amperehours, surface tension measurements, inspection and maintenance of the air pollution

control devices, and initial and ongoing compliance status reports. Samples of chromic

acid solution were collected by ARB in the Bay Area, Sacramento, San Diego, and the

San Joaquin Valley and sent to a laboratory for surface tension analysis. Sample results

were returned to ARB and then transmitted to the Districts. In the South Coast AQMD,

District inspectors collected chromic acid samples and sent them to a laboratory for

surface tension analysis. Sample results were returned to the District. Notices of

Violation (NOVs) and Notices to Comply (NTCs) were issued by district inspectors

subsequent to the inspections and sample analysis. Each District provided copies of its

inspection checklists, inspection reports, NOVs and NTCs to ARB.
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Table 1 below summarizes the number of chrome platers in each District and the

number of chrome platers inspected. In the South Coast AQMD, the 128 facilities

inspected represent the number of sources that needed to be inspected to obtain

statistically valid results with a 95% confidence level. In the other four districts, almost

all permitted chrome platers were inspected. Inspection results from the 188 facilities

inspected are sufficient to draw conclusions about compliance in this source category on

a statewide basis.

Table 1

Facility Inspection Summary

District Number of Permitted Chrome Platers Number of Chrome Platers Inspected

Bay Area 23 21

Sacramento 6 6

San Diego 13 12

San Joaquin Valley 21 21

South Coast 171 128

Totals 234 188

Types of Violations

Violations documented during inspections can be broadly divided into three

categories: direct excess emission violations (DEEVs), emission-related violations

(ERVs) and non-emissions related violations (NERVs).

Direct excess emission violations occur when an emission standard is violated in

the presence of an inspector based on visual observation, record review or sample

analysis. Examples of DEEVs are: failure to install an add-on control device or not

maintaining the surface tension of chromic acid solution below 45 dynes/centimeter.

Emission-related violations are violations that could result in excess hexavalent

chromium emissions to the atmosphere. Examples of ERVs are: insufficient polyball

coverage or foam blanket thickness, no water to a scrubber, exceeding the pressure drop

across an add-on control device, failure to inspect and maintain the add-on control

device, failure to measure surface tension, failure to add fume suppressant, missing or

broken pressure drop gauges, ampere-hour meters not installed or not operating, and

failure to keep critical records such as in-house surface tension analysis results, fume

suppressant additions and operating parameters of add-on control equipment.

Non-emission related violations are administrative or procedural violations.

Examples of NERVs violations are: failure to prepare or submit an initial or ongoing

compliance status report, no operation and maintenance plan, ampere-hour meters not

hard wired, incomplete records or failure to keep non-critical records such as source test

results and outside laboratory results of surface tension analysis on-site and make them

available to the District upon request. 
4

Table 2 below illustrates the type of violations discovered during the rule

effectiveness study. This table shows each section of the ATCM, the type of violation by

section, and the number of facilities in each District violating the ATCM. Most of the

violations documented in the study pertained to monitoring, recordkeeping and reporting,

and were not contributing to “direct excess emissions” at the time of the inspection.

Table 2

Violations of the ATCM by Section & District

ATCM Section Facilities In Violation

Bay

Area

Sacramento San

Diego

San

Joaquin

South

Coast

(c) Standards – (DEE)

Specifies the method of compliance and emission limits for

hard, decorative & chromic acid anodizing facilities.

0 0 3 1 11

(d) Performance Test Requirements & Methods - (NER)

Specifies when testing must occur, approved test methods &

pre-test protocol.

0 0 0 0 1

(e) Parameter Monitoring – (ER)

Establishes monitoring frequency for ampere-hours, pressure

drop, inlet velocity pressure, surface tension, foam blanket

thickness & mechanical fume suppressants.

8 4 9 13 40

(f) Inspection & Maintenance Requirements – (ER)

Specifies what equipment needs to be inspected, at what

frequency & maintenance requirements for add-on control

devices. Specifies maintenance requirements for ampere-hour

meters and for equipment used to measure surface tension.

1 0 0 7 5

(g) Operation & Maintenance Plan Requirements – (NER)

Directs facilities subject to Section (f) to prepare an Operation

& Maintenance Plan.

1 0 0 3 30

(h) Recordkeeping – (ER/NER)

Requires facilities to keep inspection records for add-on control

devices, fume suppressants, performance tests, monitoring data,

breakdowns, excesses, facility size, fume suppressant additions

& trivalent bath components.

2 0 0 13 51

(i) Reporting – (NER)

Requires facilities to notify the district prior to performance

testing and report test results to the district. Requires facilities

to provide an initial and ongoing compliance status report to the

district and reporting requirements for facilities using trivalent

chromium baths and wetting agents.

1 0 10 15 69

Total Facilities Inspected 21 6 12 21 128
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Table 3 below summarizes the non-compliance rates among chrome plating

facilities.

Table 3

Non-Compliance Rates Among Chrome Plating Facilities

Facilities Violating

ATCM

Facilities With

ERVs

Facilities With

DEEVs

Facilities With

NERVs

District Facilities

Inspected

# % # % # % # %

Bay Area 21 8 38 3 14 0 0 8 38

Sacramento 6 4 67 1 17 0 0 4 67

San Diego 12 10 83 7 58 3 25 10 83

San Joaquin 21 17 80 14 67 1 5 17 80

South Coast 128 99 77 48 38 11 9 90 70

Totals 188 138 73 73 39 15 8 129 68

Table 4 below summarizes the non-compliance rates on a permit-unit basis. Noncompliance rates (percent in violation) among the facilities and permit units inspected

was determined by dividing the number of facilities in violation by the number inspected.

Table 4

Non-Compliance Rates Among Permit Units

Chromic Acid

Anodizing Tanks

Decorative Chrome

Tanks

Hard Chrome Tanks Add-on Control

Devices

District

Inspected % IV Inspected % IV Inspected % IV Inspected % IV

Bay Area 1 100 14 29 25 64 12 33

Sacramento 1 0 5 80 6 0 1 0

San Diego 1 100 9 100 9 11 3 0

San Joaquin 0 N/A 17 88 8 63 6 50

South Coast 40 63 93 66 122 48 73 58

Totals 43 65 128 73 170 48 95 53

% IV = Percentage of permit units inspected that were in violation of ATCM

Findings

Violations of the ATCM by Section

1) 8% of the facilities violated Section (c) - Standards.

2) One facility violated Section (d) – Performance Test Requirements/Methods.

3) 39% of the facilities violated Section (e) – Parameter Monitoring.

4) 7% of the facilities violated Section (f) – Inspection & Maintenance.

5) 18% of the facilities violated Section (g) - Operation & Maintenance.

6) 35% of the facilities violated Section (h) – Recordkeeping.

7) 50% of the facilities violated Section (i) – Reporting.
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Non-Compliance Rates Among Chrome Plating Facilities

1) 73% violated the ATCM.

2) 39% had emission-related violations.

3) 68% had non-emission related violations.

4) 8% had direct excess emissions.

Non-Compliance Rates Among Permit Units

1) 65% of the chromic acid tanks violated the ATCM.

2) 73% of the decorative chrome tanks violated the ATCM.

3) 48% of the hard chrome tanks violated the ATCM.

4) 53% of the add-on control devices violated the ATCM.

Data Analysis

Overall Non-Compliance Rates: Inspection data collected from joint inspections

of 188 chrome plating facilities suggests that most (73%) of the facilities violated at least

one section of the ATCM. Non-compliance rates were high among all tank categories,

i.e., chromic acid anodizing – 65%, decorative chrome – 73% and hard chrome – 48%.

Non-Compliance Rates among Add-On Control Devices: Hard chrome plating

operations using more than 500,000 ampere-hours a year are required to use an add-on

control device and conduct a source test to determine its emission rate. Most decorative

chrome platers choose to comply with the emission standards by using a chemical fume

suppressant with a wetting agent to reduce the surface tension of the bath solution below

45 dynes per centimeter. However, a few decorative chrome plating, chromic acid

anodizing and trivalent chrome plating operations have opted to use add-on control

devices to comply with the emission standards. These add-on control devices are

composite mesh pad scrubbers, pack bed scrubbers or high efficiency particulate

arrestors. All of the 95 add-on control devices inspected during this study had previously

been source tested and were found to be operating within their allowable emission rate

limits. However, there is no guarantee that these control devices will continue to operate

within their allowable emission limits unless they are inspected and maintained according

to the schedule contained in Section (f)(1) of the ATCM. In order to show compliance

with Section (f)(1), facilities must prepare an Operation and Maintenance Plan as

required by Section (g) of the ATCM. Seven of the 95 add-on control devices inspected

violated Section (f)(1) and 32 violated Section (g) of the ATCM.

Two hard chrome plating facilities in the South Coast were operating without addon control devices. Both facilities were using chemical fume suppressants and exceeded

500,000 ampere-hours a year. The District issued NOVs to these facilities. One facility

attended an abatement hearing and installed a control device. The other facility

conducted a source test to determine its emission rate and applied to the U.S. EPA to

continue to use a chemical fume suppressant as an equivalent alternative to an add-on

control device. Official confirmation by U.S. EPA is pending.
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Emission Standards Violation Rate: Only 8 percent (15/188) of the facilities

inspected violated Section (c) of the ATCM (Emission Standards). This section of the

ATCM specifies the method of compliance and emission limits for hard, decorative, and

chromic acid anodizing facilities. Actual source testing of facilities to determine

compliance of stack outlet emissions with the ATCM standards was not conducted as part

of this study. However, ARB staff did review the compliance history of every inspected

facility equipped with add-on control devices to ensure that they had been successfully

source tested in the past. Two hard chrome plating violated Section (c) by not installing

add-on control devices. Eleven decorative chrome plating facilities, one small hard

chrome, and one chromic acid anodizing facility exceeded the 45 dynes per centimeter

surface tension standard.

Recordkeeping Violation Rate: Thirty-five percent (66/188) of the facilities

inspected violated Section (h) – Recordkeeping. Section (h) requires owners and

operators to keep inspection records of add-on control devices, performance test records,

monitoring data records (cumulative rectifier usage, pressure drop, inlet velocity

pressure, surface tension, foam blanket thickness), equipment breakdowns, excess

emissions, fume suppressant additions and trivalent bath components. Recordkeeping is

necessary to show that the facility is operating in compliance with the ATCM and

without records, inspectors cannot verify compliance. It should be noted that this study

was conducted soon after the ATCM became effective (April 14, 1999) and prior

experience has shown that violations, especially recordkeeping violations, are the highest

right after a rule becomes effective. Violations will decrease as the regulated industry

learns how to comply. Towards this end, Districts should take a proactive approach

through source education and outreach. It may be necessary for Districts to provide

facilities with standardized recordkeeping forms and instructions on how to complete the

forms in order to ensure compliance with this section of the ATCM.

Parameter Monitoring Violation Rate: Thirty-nine percent (74/188) of the

facilities inspected violated Section (e) – Parameter Monitoring. Section (e) requires

owners and operators to monitor ampere-hours, pressure drop, inlet velocity pressure,

surface tension, foam blanket thickness and polyball or similar mechanical fume

suppressant coverage of the tank surface. Failure to monitor these parameters can result

in excess chromium emissions to the atmosphere. Inspectors found three add-on control

devices that exceeded their pressure drop limit. An increase in pressure drop, decreases

control efficiency. In two instances inspectors found an insufficient foam blanket

thickness. In two other instances inspectors found the polyballs or polypropylene tubes

did not cover the tank surface. The control efficiency of these mechanical fume

suppressants is dependent upon complete coverage of the tank surface. These violations

will tend to reoccur unless districts conduct source education and outreach.

Reporting Violation Rate: Fifty percent (95/188) of the facilities inspected

violated Section (i) – Reporting. Section (i) requires owners and operators to submit the

results of their performance tests, initial and ongoing compliance status reports,

breakdown reports and trivalent chrome bath components to the district. The majority of

the violations were the result of facilities failing to submit an initial or ongoing
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compliance status report to the district. Initial compliance status reports (ICSR) are

prepared by each facility and show how they will comply with the requirements of the

ATCM. Ongoing compliance status reports (OCSR) are prepared annually and are

intended to show compliance with the ATCM.

Other Findings

Inspection Frequency

The frequency of inspections is often a good indicator of compliance rates and

rule effectiveness. It has been ARB’s experience that more frequent inspections result in

higher compliance rates and subsequently more effective rule implementation. In this

study, the average time in months since the last facility inspection for the five districts

was as follows: Sacramento – 6 months; Bay Area – 11 months; San Diego – 12 months;

San Joaquin Valley – 18 months and South Coast – 26 months. The percentage of

facilities violating the ATCM in these Districts is as follows: Sacramento – 67%; Bay

Area – 38%; San Diego – 83%; San Joaquin Valley – 80% and South Coast – 77%.

Chrome platers in the Bay Area had the lowest non-compliance rate (38%) among

all five districts. Bay Area AQMD inspects these facilities annually. Chrome platers in

San Diego had the highest non-compliance rate (83%) among all five districts. San

Diego County APCD also inspects these facilities annually. The difference in noncompliance rates among chrome platers in these two districts may be attributed to the fact

that the San Diego chrome platers had not been inspected since the new chrome plating

requirements became effective (April 14, 1999) and were not familiar with the

requirements of the new regulation. 

Inspector Training

Documenting violations requires inspectors to be knowledgeable about the

process they are inspecting and the regulations they enforce. Since hexavalent chromium

is a toxic compound regulated by air districts, inspectors need to be able to identify

emission points in the process and determine whether or not there is a violation before the

community is affected. Inspectors in all five districts are trained to inspect chrome

plating facilities and enforce the ATCM. However, there was some variation in the

quality of inspections between the three zones in the San Joaquin Valley. There were

differences among inspectors with respect to interpretation of the ATCM as well as

thoroughness of inspections and enforcement actions. In order to improve the quality of

these inspections and promote consistency within the District, inspectors should meet

periodically to discuss their inspections and enforcement actions.

Enforcement Actions

Generally speaking, NOVs are intended for ERVs and Notices To Comply

(NTCs) are intended for NERVs. Penalties associated with NOVs help to deter ERVs.

NTCs are not associated with penalties.
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Table 5 below shows the total number of facilities inspected, the number of

facilities with ERVs and the number of facilities receiving NOVs for ERVs. Of the 188

facilities inspected, 73 (39%) had ERVs and 41 (56%) of the facilities with ERVs

received NOVs. 

Table 5

Facilities With Emission-Related Violations

District Total Facilities

Inspected

Facilities With ERVs Facilities Receiving

NOVs For ERVs

Bay Area 21 3 3

Sacramento 6 1 1

San Diego 12 7 7

San Joaquin 21 14 9

South Coast 128 48 21

Totals 188 73 41

Bay Area AQMD, Sacramento Metropolitan AQMD and San Diego County

APCD issued NOVs to all facilities with ERVs. In the San Joaquin Valley, 64% of the

facilities with ERVs received NOVs. In the SCAQMD, 44% of the facilities with ERVs

received NOVs.

Forty-one facilities in the SCAQMD were operating without records. Thirty

facilities received NTCs and eleven received NOVs. However, in the SCAQMD, when

records are not provided upon request during an inspection and there is no direct excess

emissions violation, a NTC is issued to produce the records by a certain date. If the

records are provided and compliance determined, SCAQMD does not consider the initial

lack of records to be an emission-related violation. On the other hand, if the records are

not ultimately provided, SCAQMD agrees there is an emission-related violation and

issues a NOV. All NTCs issued by SCAQMD inspectors for failure to provide records

include a facility inspector follow-up to determine whether or not a NOV should be

issued, consistent with AQMD Rules and their Policies and Procedures. When a NOV is

warranted per District policy, one is issued. Two of the thirty facilities issued NTCs for

no records failed to produce records by the follow-up inspection and were subsequently

issued NOVs.

ARB considers the absence of records to be an emission-related violation since

without records, inspectors cannot make a compliance determination. Records that are

required by rule and permit conditions should be kept on-site and made available to the

District upon request. We realize there are situations where immediate access to records

is not always possible, e.g., records in locked storage and owner/manager not on-site.

The issuance of a NTC may be an appropriate enforcement action for this situation.

However, there are other situations where a NOV may be more appropriate because of

the nature of the records involved, time frame of missing records and no justifiable

reason why records cannot be produced during the inspection. Non-critical records, such

as source test results and outside laboratory results of surface tension analysis can be

produced at a later date without a loss of confidence as to their authenticity. Critical

records, such as in-house surface tension analysis, addition of chemical fume
10

suppressants to the plating tank, operating parameters of add-on control equipment are of

value only when field readings are recorded on a contemporaneous basis. There is no

assurance that records produced two weeks after an initial inspection are credible.

Districts should develop guidelines so that inspectors recognize these situations and take

appropriate and consistent enforcement action.

Penalty Settlement Amounts & Settlement Times

As a follow-up to the field inspections, each District was asked to provide ARB

with a summary of final case dispositions, i.e., penalty settlement amounts and settlement

dates, for facilities receiving NOVs during the inspections. This information was

provided to ARB.

ARB tabulated this information and determined the average penalty settlement

amounts and settlement times for the NOVs issued during the rule effectiveness study.

This information is summarized in Table 6 below.

Table 6

Average Penalty Settlement Amounts & Settlement Times

Districts NOVs

Issued

NOVs Settled

For a Penalty

(as of 5/3/02)

Penalties

Collected

Average Penalty

Settlement

Amount

Average

Penalty

Settlement

Time

NOVs Pending

Settlement

(as of 5/3/02)

Bay Area 10 7 $7,450 $1,064 5 Months 2

Sacramento 1 1 $840 $840 15 Months 0

San Diego 10 7 $3,700 $529 6 Months 0

San Joaquin Valley 12 10 $6,760 $676 14 Months 0

South Coast 25 21 $201,975 $9,618 12 Months 4

Totals 58 45 $215,725 $4,794 10 Months 6

It is our finding that penalty amounts vary within each district, and from district to

district for similar types of violations. Also, we believe penalties are in general too low

to act as an effective deterrent for future violations. Since hexavalent chromium is a

toxic air contaminant, it is especially important to ensure that penalties are commensurate

with the nature, scope, and seriousness of the violations. The use of meaningful penalties

should provide a financial incentive for this industry to comply with the air toxic control

measure and should create an environment where full compliance is the most costeffective option available. We recommend that districts should work together on

developing enforcement guidelines to achieve uniform and credible penalty assessments

at chrome plating facilities. ARB staff is willing to assist air districts in developing

uniform enforcement guidelines for this source category.

Parameter Monitoring

Surface Tension – Section (e)(4) of the ATCM requires owners and operators of

chrome plating facilities to measure surface tension daily for 20 operating days and

weekly thereafter. Since inspection results revealed that all of the direct excess emission

violations were due to exceedances of this standard, districts need to be able to collect
11

samples of chromic acid solution and analyze the samples to verify compliance with this

section of the ATCM. Five of the 26 chromic acid samples collected by ARB exceeded

the 45 dynes/centimeter standard. South Coast AQMD collects samples and uses an

independent laboratory to analyze them. Other districts should also take random samples

of chromic acid solution to verify compliance with the surface tension standard.

Section (e)(4) of the ATCM also requires owners and operators to monitor the

surface tension of the chrome plating or chromic acid anodizing tank that contains a

wetting agent with either a stalagmometer or tensiometer. Most chrome plating facilities

use stalagmometers to measure surface tension. Stalagmometers cost about $250. A few

facilities use tensiometers that cost several thousand dollars. ARB has been informed

that stalagmometers may not be as accurate as tensiometers. Although no test data has

been presented to ARB to support this hypothesis, it should be investigated since the 45

dynes/cm standard is very important in the control of chromium emissions. 

Operating Parameters – Sections (e)(2)(3)(5)(6) of the ATCM require owners

and operators to do parameter monitoring. Pressure drop, inlet velocity pressure, foam

blanket thickness and the use of mechanical fume suppressants are supposed to be

maintained within the range established during the performance test of the air pollution

control device. Appendix 1 of the ATCM requires facilities to record these parameters

during their performance test and Section (i)(1) requires facilities to report this

information to the district. It was noted during the field study that these parameters are

not always reported to the District. Districts should enforce this requirement and

incorporate these operating parameters into facility permits as permit conditions.

Calibration Requirements

Section (f)(2) of the ATCM requires facilities to install and maintain ampere-hour

meters according to the manufacturer’s specifications. There were only a few instances

noted during the study where inspectors enforced this requirement. Stalagmometers and

tensiometers are required to be calibrated and maintained according to the manufacturer’s

specifications, but this requirement was not widely enforced.

Permit Quality

Best Permits – The Sacramento Metropolitan AQMD incorporates all of the

requirements of the ATCM as permit conditions. Permit conditions are organized

according to the sections of the ATCM, i.e., emission limits, source testing requirements,

parameter monitoring, inspection and maintenance, operation and maintenance plan,

recordkeeping and reporting. These permits are easy to read and enforce.

Outdated Permit Conditions – In the South Coast AQMD, some permit conditions

specify the surface tension of a chromic acid bath be maintained at 63 dynes/cm or less.

In San Diego County APCD, some permits require the use of Dis-Mist NP, a chemical

fume suppressant to control surface tension. According to the manufacturer (McGeanRohco), Dis-Mist NP forms a foam blanket on the tank surface and does not contain a
12

wetting agent, although six of the nine chrome platers using Dis-Mist NP complied with

the surface tension standard. In the San Joaquin Valley Unified APCD, some decorative

chrome plating permit conditions require an anti-mist additive providing at least 95%

control of chromium emissions. The permit conditions noted above are not current with

the ATCM.

Outdated Permit Descriptions – Some permit descriptions may not match the

equipment at the facility. This may be due to a backlog in the processing of applications

for Authorities to Construct and Permits to Operate. This situation was especially true in

the SCAQMD where some applications can take up to three years to process. The

SCAQMD has made an effort through the use of agency staff and contract permit

processors to eliminate the aged permit application inventory and maintain future permit

issuance within acceptable time frames.

Recommendations

Improving Compliance with the ATCM

1) The California Air Pollution Control Officers Association should form a

committee to address the report’s findings and recommendations.

2) Increase inspection frequency to at least once every 12 months.

3) Districts should work together on developing enforcement guidelines to achieve

more uniform and credible penalty assessments at chrome plating facilities. ARB

staff is willing to assist districts in developing uniform enforcement guidelines for

this source category.

4) Provide standardized recordkeeping forms and instructions to facilities on how to

complete the forms.

5) Inspectors in the San Joaquin Valley APCD should meet periodically to discuss

their inspections and enforcement actions.

6) Districts need to identify emissions and non-emissions related recordkeeping

violations and issue NOVs for emissions-related recordkeeping violations.

7) Randomly sample and analyze chromic acid solutions to verify compliance with

the surface tension standard.

8) Require facilities to record and report the performance test values (operating

parameters) of their add-on control devices to the district and districts should

incorporate these values as permit conditions into facility permits to operate.

9) Enforce the calibration requirements for ampere-hour meters and tensiometers.

10) Permit conditions should be current with the ATCM and enforceable. Permit

descriptions should be current with the equipment at each facility.

11) Provide compliance assistance to owners and operators who continue to violate

the ATCM.

12) Investigate the issue of variation in results between stalagmometers and

tensiometers.
13

Improving the ATCM

1) Section (f) of the ATCM has inspection and maintenance requirements for

sources using chemical or mechanical fume suppressants. Stalagmometers are

required to be calibrated and maintained according to the manufacturer’s

specifications. Compliance with this section of the ATCM could not be verified

since the instrument cannot be calibrated. In order to check the accuracy of the

instrument, facility owners or operators could check the surface tension of

distilled water to see if it approximates 72 dynes/centimeter.

Program Improvements since the Study

The Districts participating in the chrome plating rule effectiveness study have

implemented a number of improvements to their programs since the study began. These

improvements are noteworthy and are listed below:

South Coast AQMD

1) Inspection frequency has been increased to no less than annually and attention is

being paid to these sources to bring compliance up to acceptable levels.

2) The District purchased a tensiometer and now has in-house capability to verify

compliance with surface tension requirements.

3) The District engaged a contractor to update permit conditions. The work is

almost complete.

4) The District has significantly eliminated the aged permit application inventory.

5) The District is ensuring that permit issuance for current permit applications are

maintained within acceptable time frames.

San Diego County APCD

1) The District has a 12-month inspection cycle.

2) The District developed standardized recordkeeping forms and instructions for

these facilities. In addition, the District’s Small Business Assistance specialist

has offered and provided individual assistance to each source.

3) The District has a specialized team responsible for inspecting chrome plating

operations and has provided training to these inspectors to ensure the ATCM is

consistently enforced.

4) The District purchased a stalagmometer and is verifying compliance with the

surface tension requirement.

5) Permit conditions require operating parameters and compliance is verified during

the annual inspection.

San Joaquin Valley Unified APCD

1) The District increased the inspection frequency of chrome platers to twice per

year in order to improve compliance rates.