- Email: [email protected]
Modern chrome compliance: An overview for finisher
Modern Chrome for Finisher
Compliance:
by Julie C. Rogers, P.C., Rogers Consulting 4205 E. Camino
de Palmas,
Tucson, Arizona
Services LLC
85711; E-mail,
T
he modern chrome plater should make careful preparations prior to starting or modifying a business to assure that the doors swing open on time and stay that way. By starting up, modifying, or upgrading a facility in a legal and proper manner, the chrome plater, chromic anodizer, or any metal finisher will avoid many problems down the road. Many of the requirements mentioned in this article, such as building occupancy codes, zoning, and sewer use permitting, apply to any metal finishing operation, not just chrome platers, and not just restricted to chrome compliance. BUILDING CODES, ZONING, AND CONSTRUCTION PERMITS The first step on the compliance pathway involves the selection or construction of the right building, in a properly zoned area. Since dealing with the developmental services department of your community may take time, the process of obtaining a Certificate of Occupancy (as well as permitting for building or modification and compliance with various building codes) should begin long before the proposed startup date. An architect can be of great help in bringing the building up to code. Most hazardous chemical or hot work operations require an “H” building occupancy code in a commercial-industrial area zoned for heavy industry. Try to avoid locations with residential-commercial zoning. FIRE CODE COMPLIANCE Compliance with local fire codes is normally achieved as part of the development services, planning, and zoning process. However, recently, some municipalities’ fire departments have implemented programs aimed not only at new facilities, but at bringing existing facilities into the loop. These programs have included hazardous materials inventory registration, on-line reporting, and business outreach programs, as well. By working with developmental services from the very beginning, the finisher can avoid later nightmares. You don’t want to replace your fume scrubber ductwork because the material was not up to code, nor do you want a fire for the same reason! Be sure to keep your fire department informed of proposed building or process modifications as they arise. November
2003
An Overview
[email protected]
SEWER USE PERMITTING Is the proposed facility being designed to minimize water consumption? Is a sewer use permit required? If the facility is closed loop, does your local municipality require a “Zero Discharge Permit?” A call to the agency regulating such matters can inform you. Whether the facility is discharging or not, the agency governing sewer use will want to be included in the process. Such agencies have small business assistance units that stand ready to advise and assist. Additional support can be obtained through a reputable consulting or engineering firm, as well. If you have opted to use the sewer for excess water disposal, chrome reduction equipment should be included in the wastewater treatment system so that chromium bearing rinsewaters can be reduced from hexavalent to trivalent chromium, and then precipitated prior to decant and discharge. Analytical costs for self-monitoring of industrial discharges must be included in the budget. Record keeping is determined by your conditions of permit, once again, so be sure to review your permit! Sewer use permitting requires several elements to substantiate that the design of the proposed waste treatment system will be adequate to the task. Typical required elements include a water flow diagram, process flow chart, a toxic organic management plan, a spill plan, and a chemical inventory. Your own regulatory agency may require even more. Many municipalities offer rebates or have financial incentive programs for water conservation efforts. MACT STANDARD COMPLIANCE Air quality regulations for chromium have generated complicated, high-profile permitting processes. Federal forms must be submitted to notify EPA of the construction or reconstruction of a new tank or a tank that has been overhauled, repaired, or replaced. One also has to notify the EPA of the intent to comply with applicable regulations, as well as notification of performance testing. Trivalent chrome baths must be registered initially, but are subject to less stringent regulation afterward. Hex chrome performance test results are submitted on a form for that purpose, and compliance status reports are also included in the reporting requirements of this air quality control 39
regulation. If you modify the actual format of the documents used to comply with the regulations, it is important that your chosen format still includes every bit of the information specified on the standard Federal form. You must pay close attention to Chromium MACT Standard record-keeping and reporting requirements. The forms mentioned above are just part of that rule. Among the paperwork requirements are record keeping of testing and monitoring that demonstrates compliance with the regulations. There are severe penalties for even minor compliance discrepancies. These “Work Practice Standards” and record-keeping logs are incorporated into the Operation and Maintenance (O&M) Plan for the specific regulated process - in this case, chrome plating or anodizing. Whether hexavalent chromium fume control is accomplished with a scrubber or wetting agent fume suppressant, work practices are described in the O&M Plan, with maintenance procedures and log sheets attached. O&M Plans are usually submitted with the Air Quality Permit Application or Modification Information Package.
GEe AU
THE FACTS
NAMF and AESF offer some excellent courses and publications on basic electroplating, hard chromium electroplating, equipment and processes, and many related topics. Back copies of Metal Finishing are another treasure trove of practical information. The important point is to use all the information resources at your disposal to do research before making any equipment purchase. Every hour of research will pay for itself many times over. Appropriate equipment and good process control lower pollution, as well as lowering your labor, energy, and supply bills. Rework is a direct cause of pollution. Think about it! MAKE
A DECISION
ON FUME
CONTROL
When power is applied to a chromium bath, the reaction at the cathode generates bubbles that burst, emitting chrome into the atmosphere. Hexavalent chromium, generated in the reaction and emitted by the bursting bubbles, has been definitively proven to be carcinogenic for humans. Fume control is by the EPA and that agency’s local enforcement agencies through regulations set forth
Designed specifically for the needs of the Metal Finishing an,d Electroplating industry...
USEPA-approved Method O/A1677, our innovative distillationless method for cyanide analysis is a valuable and timesaving tool that eliminates potential interferences, increases precision and accuracy, improves laboratory safety, lowers costs, and eliminates the need for dangerous reagents such as pyridine and barbituric acid. 01 Analytical offers the CNSolution and the Flow Solution@ IV to implement this cyanide method. The FS-IV offers application flexibility and is capable of performing segmented flow analysis (SFA) and/or flow injection analysis (FIA).01Analytical’sCNSolution and FlowSolution IV provide FAST,ACCURATE & INTERFERENCE FREE RESULTS!
www.oico.com
1(800)653-1711 1(979)690-1711 oimailQoico.com lrcle U78 on reader 40
Information
A World of Solutions card or go to www.thru.to/webconnect Metal
Finishing
in 40 CFR 63 (N). An O&M Plan for each tank or fume scrubber is required for either control technology. You must name the type of fume control you will use in your O&M Plan, Permit Application, or Modification, as well as the federal registration forms mentioned earlier. Hard chrome plating fume control usually involves scrubbing the emissions from the tanks with a mesh pad or composite scrubber. The equipment must operate efficiently enough to pass the 0.015 mg/dscm Cr-6 federally enforceable limit in a monitored performance test by a licensed testing service. Once the parameters for compliant operation have been determined during the initial performance test, the O&M Plan can be finalized and adhered to during future operation. Monitoring of pressure drop, water flow, pH, and other parameters may be incorporated into the monitoring and record-keeping parts of the Plan. If you use wetting agent fume suppressant, the method most commonly used for decorative chrome plating or Type I anodizing, the requirements for that technology must be met, as set forth in 40 CFR 63 (N). Fume suppressants are surfactants, which lower emissions by lowering the surface tension of the
chrome bath. You must enter into the log sheet additions of wetting agent, surface tension monitoring test results, tank operating time, the time of day of the addition, who performed the test, the condition of the equipment and tank, and other data that may be required at the local level or in your Conditions of Permit. Be sure to review yourpermit, as the time you have to contest anything you want to change, do not like, or do not understand, is limited. Recent changes to the regulation allow the use of wetting agent (surfactant) fume control for hard chromium plating tanks. The impact of wetting agents on hard chrome electroplated parts is a subject of much debate, with some people contending that additions to the plating bath increase workpiece pitting. The wetting agent must lower the chrome bath surface tension to 45 dynes/cm or less if measured with a Traube stalagmometer and 35 dynes/cm or less if measured with a tensiometer. The regulation was modified to accommodate the difference in results between the two devices. Training materials are available on CD ROM and in book form to help teach correct methods of measuring surface tension.
tiastwter MetalComplhn~eProbkms?
Try F loccid”it!!!! Proven performance in achieving the lowest levels 13metal removal and reducing cost. Use of our Floccin products has helped many companies meet their compliance standards and save $$$, too. Look at typical single treatment results 0w-Q Chromium Lead Nickel Zinc
8.929 0.690 10.310 18 .O#
eo.03 4.10 4.05 0.018
Contact at our website wecIeanwater.com or call us to see v&at wvecan do for you. (377) 9651577
- - 9PnPs I -. I -
ZDX series Bearing-free, seal-less vertical pumps
P-W
High volume,
seal-less
drum pumps
Need a quality, dependable pump or filter in a hurry? Most orders received by 12 noon can be shipped the same day at no additional charge!
40508 Greenwood Way O&hurst. CA93644 Tel: 800-645-0500
l
631-435-0530
E-mail: [email protected]
:ircle 031 on reader November
2003
information
card or go to www.thru.to/webconnect
Circle
064 on reader
information
l l
Fax:
Website:
631-435-0654
www.sethco.com
card or go to www.thru.to/webconnect 41
HAZARDOUS WASTE Standard hazardous waste regulations apply to chrome process waste streams, but with a twist! The lead byproducts of the chrome plating process are regulated under newly promulgated Form R “coincidental manufacturing” reporting regulations. A Form R eligibility review should be conducted annually prior to the filing deadline of July 1. Spent anodes that are shipped out need to be included in the review, as well as the lead content of the sludge shipped off-site. For every 64 pounds of anodic lead replaced in a year, 100 pounds of lead compounds are generated as a component of the sludge and this must be reported. Airborne emissions are reportable also, although smaller facilities do not melt enough lead to trigger this aspect of the reporting requirements often. Obviously, it is wise to begin the accumulation of information for Form R obligations throughout the year prior to the filing deadline, rather than trying to reconstruct records a year after the fact and at the last minute! EPA has generated Form 8700-12, which is traditionally submitted for the facility at start-up to register the facility as a Hazardous Waste Generator of the generator status noted on the form. This form must also be submitted whenever the facility’s generator status, waste stream, or ownership changes. A Hazardous Waste Generator Registration Number cannot be taken with you if
you move. A new one must be applied for at the new location. After submittal, an EPA Hazardous Waste Generator Number will be issued to you, and must be used on all hazardous wastes shipped from the facility. SWPPP SWPPP - Storm Water Pollution Prevention Plan and Aquifer Protection regulations must be remembered, as well. While the facility is in the design stage, thought should be given to chemical storage or handling procedures that could impact storm water quality. Chemicals and metals stored on site should be inventoried and a Storm Water Pollution Prevention Plan with Notice of Intent or a No Exposure Certification should be completed and filed with EPA or the agency delegated as the local authority for this regulation’s enforcement, SUMMING IT ALL UP While the array of regulations confronting the chrome finisher in our modern world can seem daunting, with proper planning and foresight, every hurdle can be overcome. Despite the regulatory compliance requirements, chromium metal finishing will continue to be a vital part of our industry. By doing the proper research and by laying a foundation of honesty and trust with your local regulators, you will have gone a long way to ensure a prosperous and compliant future for your chrome finishing facility. nfw
Infrared Ovens Convection Ovens Cooling Chambers Flash Off Tunnels Finishing Cells Conveyors Lift Tables Controls and more. .._ . i :., .- ._ ,:’ _. ,:’ _. B 2@’)& E ‘
How much should you pay for reject-free plating 2 Send us a drawing of
Rapid adsorption/filtration and insoluble metals
and
Clean,
easy-to-use
Improves
dust-free plating
High hydraulic flowrate and
and quality
IT!
SERFILCO” PF-13
Circle 062 on reader information or go to www.thru.to/webconnect
42
card
consistency improves service life
Ca//800-249-1990fora Sample!
Relied on by customers, large and small, for over 20 years. You can depend on us too. Blasdel
FAX: 847-559-1995 or CALLTOLL-FREE 800-323-5431
and
permeability extends bath
FREE ECOSORB
WE GUARANTEE
of soluble organics
Enterprises, 800-661-3313 www.blasdel.net
Inc.
Circle 009 on reader information or go to www.thru.to/webconnect
card
ZOOLake Drive, Glasgow, DE 19702.3319 'el.: 302-731-1700 800-249-1990 Fax: 302-731-1707 Websile: w.gravertech.com
Circle 027 on reader information or go to www.thru.to/webconnect Metal
card Finishing
Compliance:
by Julie C. Rogers, P.C., Rogers Consulting 4205 E. Camino
de Palmas,
Tucson, Arizona
Services LLC
85711; E-mail,
T
he modern chrome plater should make careful preparations prior to starting or modifying a business to assure that the doors swing open on time and stay that way. By starting up, modifying, or upgrading a facility in a legal and proper manner, the chrome plater, chromic anodizer, or any metal finisher will avoid many problems down the road. Many of the requirements mentioned in this article, such as building occupancy codes, zoning, and sewer use permitting, apply to any metal finishing operation, not just chrome platers, and not just restricted to chrome compliance. BUILDING CODES, ZONING, AND CONSTRUCTION PERMITS The first step on the compliance pathway involves the selection or construction of the right building, in a properly zoned area. Since dealing with the developmental services department of your community may take time, the process of obtaining a Certificate of Occupancy (as well as permitting for building or modification and compliance with various building codes) should begin long before the proposed startup date. An architect can be of great help in bringing the building up to code. Most hazardous chemical or hot work operations require an “H” building occupancy code in a commercial-industrial area zoned for heavy industry. Try to avoid locations with residential-commercial zoning. FIRE CODE COMPLIANCE Compliance with local fire codes is normally achieved as part of the development services, planning, and zoning process. However, recently, some municipalities’ fire departments have implemented programs aimed not only at new facilities, but at bringing existing facilities into the loop. These programs have included hazardous materials inventory registration, on-line reporting, and business outreach programs, as well. By working with developmental services from the very beginning, the finisher can avoid later nightmares. You don’t want to replace your fume scrubber ductwork because the material was not up to code, nor do you want a fire for the same reason! Be sure to keep your fire department informed of proposed building or process modifications as they arise. November
2003
An Overview
[email protected]
SEWER USE PERMITTING Is the proposed facility being designed to minimize water consumption? Is a sewer use permit required? If the facility is closed loop, does your local municipality require a “Zero Discharge Permit?” A call to the agency regulating such matters can inform you. Whether the facility is discharging or not, the agency governing sewer use will want to be included in the process. Such agencies have small business assistance units that stand ready to advise and assist. Additional support can be obtained through a reputable consulting or engineering firm, as well. If you have opted to use the sewer for excess water disposal, chrome reduction equipment should be included in the wastewater treatment system so that chromium bearing rinsewaters can be reduced from hexavalent to trivalent chromium, and then precipitated prior to decant and discharge. Analytical costs for self-monitoring of industrial discharges must be included in the budget. Record keeping is determined by your conditions of permit, once again, so be sure to review your permit! Sewer use permitting requires several elements to substantiate that the design of the proposed waste treatment system will be adequate to the task. Typical required elements include a water flow diagram, process flow chart, a toxic organic management plan, a spill plan, and a chemical inventory. Your own regulatory agency may require even more. Many municipalities offer rebates or have financial incentive programs for water conservation efforts. MACT STANDARD COMPLIANCE Air quality regulations for chromium have generated complicated, high-profile permitting processes. Federal forms must be submitted to notify EPA of the construction or reconstruction of a new tank or a tank that has been overhauled, repaired, or replaced. One also has to notify the EPA of the intent to comply with applicable regulations, as well as notification of performance testing. Trivalent chrome baths must be registered initially, but are subject to less stringent regulation afterward. Hex chrome performance test results are submitted on a form for that purpose, and compliance status reports are also included in the reporting requirements of this air quality control 39
regulation. If you modify the actual format of the documents used to comply with the regulations, it is important that your chosen format still includes every bit of the information specified on the standard Federal form. You must pay close attention to Chromium MACT Standard record-keeping and reporting requirements. The forms mentioned above are just part of that rule. Among the paperwork requirements are record keeping of testing and monitoring that demonstrates compliance with the regulations. There are severe penalties for even minor compliance discrepancies. These “Work Practice Standards” and record-keeping logs are incorporated into the Operation and Maintenance (O&M) Plan for the specific regulated process - in this case, chrome plating or anodizing. Whether hexavalent chromium fume control is accomplished with a scrubber or wetting agent fume suppressant, work practices are described in the O&M Plan, with maintenance procedures and log sheets attached. O&M Plans are usually submitted with the Air Quality Permit Application or Modification Information Package.
GEe AU
THE FACTS
NAMF and AESF offer some excellent courses and publications on basic electroplating, hard chromium electroplating, equipment and processes, and many related topics. Back copies of Metal Finishing are another treasure trove of practical information. The important point is to use all the information resources at your disposal to do research before making any equipment purchase. Every hour of research will pay for itself many times over. Appropriate equipment and good process control lower pollution, as well as lowering your labor, energy, and supply bills. Rework is a direct cause of pollution. Think about it! MAKE
A DECISION
ON FUME
CONTROL
When power is applied to a chromium bath, the reaction at the cathode generates bubbles that burst, emitting chrome into the atmosphere. Hexavalent chromium, generated in the reaction and emitted by the bursting bubbles, has been definitively proven to be carcinogenic for humans. Fume control is by the EPA and that agency’s local enforcement agencies through regulations set forth
Designed specifically for the needs of the Metal Finishing an,d Electroplating industry...
USEPA-approved Method O/A1677, our innovative distillationless method for cyanide analysis is a valuable and timesaving tool that eliminates potential interferences, increases precision and accuracy, improves laboratory safety, lowers costs, and eliminates the need for dangerous reagents such as pyridine and barbituric acid. 01 Analytical offers the CNSolution and the Flow Solution@ IV to implement this cyanide method. The FS-IV offers application flexibility and is capable of performing segmented flow analysis (SFA) and/or flow injection analysis (FIA).01Analytical’sCNSolution and FlowSolution IV provide FAST,ACCURATE & INTERFERENCE FREE RESULTS!
www.oico.com
1(800)653-1711 1(979)690-1711 oimailQoico.com lrcle U78 on reader 40
Information
A World of Solutions card or go to www.thru.to/webconnect Metal
Finishing
in 40 CFR 63 (N). An O&M Plan for each tank or fume scrubber is required for either control technology. You must name the type of fume control you will use in your O&M Plan, Permit Application, or Modification, as well as the federal registration forms mentioned earlier. Hard chrome plating fume control usually involves scrubbing the emissions from the tanks with a mesh pad or composite scrubber. The equipment must operate efficiently enough to pass the 0.015 mg/dscm Cr-6 federally enforceable limit in a monitored performance test by a licensed testing service. Once the parameters for compliant operation have been determined during the initial performance test, the O&M Plan can be finalized and adhered to during future operation. Monitoring of pressure drop, water flow, pH, and other parameters may be incorporated into the monitoring and record-keeping parts of the Plan. If you use wetting agent fume suppressant, the method most commonly used for decorative chrome plating or Type I anodizing, the requirements for that technology must be met, as set forth in 40 CFR 63 (N). Fume suppressants are surfactants, which lower emissions by lowering the surface tension of the
chrome bath. You must enter into the log sheet additions of wetting agent, surface tension monitoring test results, tank operating time, the time of day of the addition, who performed the test, the condition of the equipment and tank, and other data that may be required at the local level or in your Conditions of Permit. Be sure to review yourpermit, as the time you have to contest anything you want to change, do not like, or do not understand, is limited. Recent changes to the regulation allow the use of wetting agent (surfactant) fume control for hard chromium plating tanks. The impact of wetting agents on hard chrome electroplated parts is a subject of much debate, with some people contending that additions to the plating bath increase workpiece pitting. The wetting agent must lower the chrome bath surface tension to 45 dynes/cm or less if measured with a Traube stalagmometer and 35 dynes/cm or less if measured with a tensiometer. The regulation was modified to accommodate the difference in results between the two devices. Training materials are available on CD ROM and in book form to help teach correct methods of measuring surface tension.
tiastwter MetalComplhn~eProbkms?
Try F loccid”it!!!! Proven performance in achieving the lowest levels 13metal removal and reducing cost. Use of our Floccin products has helped many companies meet their compliance standards and save $$$, too. Look at typical single treatment results 0w-Q Chromium Lead Nickel Zinc
8.929 0.690 10.310 18 .O#
eo.03 4.10 4.05 0.018
Contact at our website wecIeanwater.com or call us to see v&at wvecan do for you. (377) 9651577
- - 9PnPs I -. I -
ZDX series Bearing-free, seal-less vertical pumps
P-W
High volume,
seal-less
drum pumps
Need a quality, dependable pump or filter in a hurry? Most orders received by 12 noon can be shipped the same day at no additional charge!
40508 Greenwood Way O&hurst. CA93644 Tel: 800-645-0500
l
631-435-0530
E-mail: [email protected]
:ircle 031 on reader November
2003
information
card or go to www.thru.to/webconnect
Circle
064 on reader
information
l l
Fax:
Website:
631-435-0654
www.sethco.com
card or go to www.thru.to/webconnect 41
HAZARDOUS WASTE Standard hazardous waste regulations apply to chrome process waste streams, but with a twist! The lead byproducts of the chrome plating process are regulated under newly promulgated Form R “coincidental manufacturing” reporting regulations. A Form R eligibility review should be conducted annually prior to the filing deadline of July 1. Spent anodes that are shipped out need to be included in the review, as well as the lead content of the sludge shipped off-site. For every 64 pounds of anodic lead replaced in a year, 100 pounds of lead compounds are generated as a component of the sludge and this must be reported. Airborne emissions are reportable also, although smaller facilities do not melt enough lead to trigger this aspect of the reporting requirements often. Obviously, it is wise to begin the accumulation of information for Form R obligations throughout the year prior to the filing deadline, rather than trying to reconstruct records a year after the fact and at the last minute! EPA has generated Form 8700-12, which is traditionally submitted for the facility at start-up to register the facility as a Hazardous Waste Generator of the generator status noted on the form. This form must also be submitted whenever the facility’s generator status, waste stream, or ownership changes. A Hazardous Waste Generator Registration Number cannot be taken with you if
you move. A new one must be applied for at the new location. After submittal, an EPA Hazardous Waste Generator Number will be issued to you, and must be used on all hazardous wastes shipped from the facility. SWPPP SWPPP - Storm Water Pollution Prevention Plan and Aquifer Protection regulations must be remembered, as well. While the facility is in the design stage, thought should be given to chemical storage or handling procedures that could impact storm water quality. Chemicals and metals stored on site should be inventoried and a Storm Water Pollution Prevention Plan with Notice of Intent or a No Exposure Certification should be completed and filed with EPA or the agency delegated as the local authority for this regulation’s enforcement, SUMMING IT ALL UP While the array of regulations confronting the chrome finisher in our modern world can seem daunting, with proper planning and foresight, every hurdle can be overcome. Despite the regulatory compliance requirements, chromium metal finishing will continue to be a vital part of our industry. By doing the proper research and by laying a foundation of honesty and trust with your local regulators, you will have gone a long way to ensure a prosperous and compliant future for your chrome finishing facility. nfw
Infrared Ovens Convection Ovens Cooling Chambers Flash Off Tunnels Finishing Cells Conveyors Lift Tables Controls and more. .._ . i :., .- ._ ,:’ _. ,:’ _. B 2@’)& E ‘
How much should you pay for reject-free plating 2 Send us a drawing of
Rapid adsorption/filtration and insoluble metals
and
Clean,
easy-to-use
Improves
dust-free plating
High hydraulic flowrate and
and quality
IT!
SERFILCO” PF-13
Circle 062 on reader information or go to www.thru.to/webconnect
42
card
consistency improves service life
Ca//800-249-1990fora Sample!
Relied on by customers, large and small, for over 20 years. You can depend on us too. Blasdel
FAX: 847-559-1995 or CALLTOLL-FREE 800-323-5431
and
permeability extends bath
FREE ECOSORB
WE GUARANTEE
of soluble organics
Enterprises, 800-661-3313 www.blasdel.net
Inc.
Circle 009 on reader information or go to www.thru.to/webconnect
card
ZOOLake Drive, Glasgow, DE 19702.3319 'el.: 302-731-1700 800-249-1990 Fax: 302-731-1707 Websile: w.gravertech.com
Circle 027 on reader information or go to www.thru.to/webconnect Metal
card Finishing