EPA Review of Chromium Electroplating Air Emissions Rule May Result in Burdensome and Unachievable Standards

More stringent emissions levels for hex chrome baths could have a major economic impact on finishers.

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 In 1995, EPA issued the chromium electroplating maximum achievable control technology (MACT) standard that applies to hazardous air pollutant (HAP) emissions from decorative and hard chromium electroplating and chromic acid anodizing operations. This standard, also amended in 2004, includes both an emissions limits and a surface tension standard to control emissions of hexavalent chromium. Pursuant to the Clean Air Act, EPA is required to conduct a residual risk assessment and technology review of the rule every eight years. 

As part of its review and assessment process, EPA issued a proposed regulation in October 2010. While EPA indicated that no new control technologies are available to control hexavalent chromium emissions, the agency suggested there was a potential residual risk to an exposed population of approximately 14 million Americans. The proposed rule included a set of revised work practices and a three-year phase-out of PFOS-based fume suppressants that are used to control hex chrome emissions. The NASF presented data and other comments to EPA and the White House Office of Management and Budget that demonstrated that EPA had relied on flawed data and had over-estimated the residual risk posed by emissions from chromium electroplating and anodizing operations. As a result, EPA concluded that the risk posed by the existing emissions of hexavalent chromium from plating and anodizing was not significant.

EPA had been working toward a court-ordered deadline to finalize the proposed changes by June 30, 2011. However, the agency dramatically changed course, and is now considering significantly tighter standards. Because the industry’s performance in controlling emissions has been so successful, EPA believes that more-stringent emissions limits and surface tension levels are justified based on the existing control technologies in place. EPA officials have hinted that the agency may lower the current emission limits by up to two-thirds below the level of the current standard and reduce the surface tension standard. Accordingly, EPA is delaying the deadline for the final regulation and reopening the rule to take comment in the coming months. 
NASF is currently in the process of collecting data and other technical information regarding the control of hexavalent chromium emissions, consulting with industry experts, and assessing the potential impact of EPA’s recommended approach to the chromium electroplating MACT standard, including a significant economic impact on many small businesses. NASF will also be meeting with EPA officials in the coming weeks to discuss the development of a new proposed regulation based on reliable and accurate information. 
For more information on this proposed regulation and how it may impact chromium electroplating and anodizing operations, contact Christian Richter or Jeff Hannapel

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