The U.S. Environmental Protection Agency has finished reviewing its “National Emission Standards for Hazardous Air Pollutant Emissions” regulations and decided in September that chromium air emissions regulations will stay the same.
That decision was applauded by the National Association of Surface Finishers, who had been working with the EPA for several years on air emission controls for chromium electroplating and anodizing operations.
“After two years of discussions with EPA, NASF achieved a victory for the industry, the environment and the public by demonstrating to the agency and the White House that NASF and its member companies are operating safely, and that no further air emission controls are necessary,” says the NASF in a statement.
There will still be a 3-year phase out of PFOS-based (perfluorooctanesulfonic acid) mist suppressants, which the NASF had supported through its ‘Sustainable Technology Initiative’ it had presented to the EPA. The NASF said those self-policing practices had already reduced chromium emissions from 173 tons to below 0.5 tons annually.
“For the hard chromium electroplating, decorative chromium electroplating, chromium anodizing, and steel pickling—HCl process facilities and hydrochloric acid regeneration plants, MACT (Maximum Achievable Control Technology) standards source categories, we propose that the MACT standards provide an ample margin of safety to protect public health and prevent adverse environmental effects,” the EPA said in its ruling.
The biggest win may have come in the EPA’s realization that it used flawed data in its original rules several years ago, a point that many finishers and trade groups had been complaining about for some time.
“In working with EPA, the White House and the Small Business Administration’s Office of Advocacy, NASF successfully corrected EPA’s initial flawed analysis that overestimated chromium emissions and the risks associated with those emissions,” says Christian Richter, NASF executive director.
The original data the EPA used in 2005 included 166 plants and didn’t differentiate by size – thus one size fit all when the agency tried to estimate the amount of emissions being put out by the plants. After cajoling by the NASF, the EPA reformulated its testing and used over 1,600 shops in its new data set, developing a new ‘model’ shop based on small, medium and large size shops.
“In reviewing available emissions data, we found that, while the large plant emission factors adequately represent the average chromium emissions from known large decorative chromium electroplating and large chromium anodizing facilities, they are not representative of the average chromium emissions from large hard chromium electroplating facilities,” the EPA says in the new rules.
The emission factor for large hard chromium electroplating developed for the original MACT standard was 35.3 lbs/yr. The EPA quickly realized that number was wrong when it saw its new data and the numbers show MACT emission averages of 0.015 milligrams per dry standard cubic meter (mg/dscm) comes to 23.6 lbs/yr, or about 1/3rd of the original estimate.
“We find that this emissions factor is unrealistically high and does not represent the average level of emissions for large facilities as we would expect to see under the current MACT standard,” the EPA says.
“Moreover, the available data on actual emissions for hard chromium electroplating plants indicate there are only four plants with annual emissions greater than 10 lbs/yr.,” the EPA says. “As a result, we determined that the large size model plant emissions factor, as defined for the original MACT standard, is not representative of existing large hard chromium electroplating facilities on a nationwide basis.”
Richter says he is appreciative that the EPA saw the numbers in the platers’ favor, and that the industry is significantly reducing its most dangerous outputs.
“The potential risks to human health have been substantially and effectively reduced, so additional control technologies were not warranted,” he says.
For more information, visit epa.gov