CHROME PLATING AND CHROMIC ACID ANODIZING SURVEY · CHROME PLATING AND CHROMIC ACID ANODIZING SURVEY The California Air Resources Board (CARB) is working on amendments to the Hexavalent

CHROME PLATING AND CHROMIC ACID ANODIZING SURVEY

The California Air Resources Board (CARB) is working on amendments to the Hexavalent Chromium Airborne Toxic Control Measure for Chrome Plating and Chromic Acid Anodizing Operations (Chrome Plating ATCM). As part of that effort, we are collecting information on facility operating practices, including tank process information, grinding, polishing, compressed air operations, housekeeping, chemical fume suppressants, and other facility information. Information collected from the Survey will help us in evaluating the need for modifying existing or proposing new regulatory measures. The information gained from this Survey will provide us the latest information and technologies, costs, and operational practices used by chrome platers and chromic acid anodizers in California.

August 2018

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CHROME PLATING AND CHROMIC ACID ANODIZING SURVEY

TABLE OF CONTENTS Section Page

I. Frequently Asked Questions ............................................................................. 3 II. Survey Forms ...................................................................................................... 4

Part 1. Facility and Contact Information ......................................................... 5 Part 2. Tank and Operation Information

A. Instructions for Tank Information ................................................... 6 B. Tank Information ............................................................................ 10 C. Operation Information .................................................................... 16 D. Cost Information ............................................................................. 18

Part 3. Buffing, Grinding, Polishing, and Compressed Air Operations ....... 19 Part 4. Housekeeping ...................................................................................... 20 Part 5. Wastewater Processing ....................................................................... 21 Part 6. Chemical Fume Suppressants ............................................................ 22 Part 7. Building, Stack, and Plating Schedule Information .......................... 23 Part 8. Additional or Proactive Control Measures ......................................... 24 Part 9. Facility Diagram ................................................................................... 25

III. Confidential Information Submittal Form ....................................................... 27

Please feel free to contact one of the following staff for questions concerning the survey.

Michelle Komlenic Phone: (916) 322-3926 Email: [email protected]

Maria Vacaru Phone: (916) 322-7433 Email: [email protected]

How to Complete the Survey • Online – Complete an online version of the survey at:

https://www.surveygizmo.com/s3/4437709/Chrome-Plating-and-Anodizing-Acid-Survey• Or complete the survey from the Program website at:

https://www.arb.ca.gov/toxics/chrome/chrome.htmand email to: Maria Vacaru ([email protected]),or mail to:

California Air Resources Board Attention: Maria Vacaru

TTD/RRB/TCS – 7th Floor P.O. Box 2815

Sacramento, CA 95812-2815 Complete and mail the survey by September 10, 2018

mailto:[email protected]


https://www.arb.ca.gov/toxics/chrome/chrome.htm


https://www.surveygizmo.com/s3/4437709/Chrome-Plating-and-Anodizing-Acid-Survey

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Chrome Plating and Chromic Acid Anodizing Survey

Section I

Frequently Asked Questions

Who needs to complete this Survey?

Owner/operators of facilities that conduct chrome plating or chromic acid anodizing operations are required to fill out this Survey.

Why do we need to fill out this Survey?

CARB staff will be amending the Chrome Plating ATCM to address recent findings showing high levels of hexavalent chromium exposure in local communities. Recent studies in the South Coast Air Basin have found that some chrome plating and chromic acid anodizing facilities still pose an unacceptable health risk to nearby communities. In addition, amendments are needed to align with the United States Environmental Protection Agency’s regulation on National Emission Standards for Hazardous Air Pollutants – Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks. This Survey will help us better understand your current operating practices and help us in determining the best available and feasible options for reducing hexavalent chromium emissions. It is very important that we collect valid and accurate data to ensure that our rule amendments are based on the best information available.

Does CARB have legal authority to request the Survey information?

Yes. California Health and Safety Code sections 39607, 39701, 41511, and title 17, California Code of Regulations section 91100 authorize CARB to require owners and operators of sources of air pollution to submit information needed to help CARB estimate atmospheric emissions of toxic air pollutants and to carry out its emissions reduction responsibilities.

What will CARB do with the completed Survey?

The results of the Survey will help determine the appropriate regulatory amendments to CARB’s Chrome Plating ATCM. Your participation ensures that your company information is accurately represented in the rulemaking process. A confidentiality statement is included at the end of the Survey for those who desire to keep their information confidential.

How does CARB treat the submittal of confidential business information?

Information you mark as confidential will be kept confidential, pursuant to California Code of Regulations, title 13, section 91000 et seq. All information marked confidential is stored in locked file cabinets and will only be accessible to authorized staff.

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Section II

Survey Forms

(These are the forms you will complete and return to CARB)

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PART 1. Facility and Contact Information

Facility Name: Facility Type (check all that apply) : Hard Decorative Chromic Acid Anodizing Trivalent

Facility Address: City:

State: Zip Code:

Facility Mailing Address (only if different from facility address):

Contact Person: Title:

Phone: Email Address:

If you prefer future communication in a language other than English, please specify language: (e.g., Spanish, Hmong, etc.)

If interested in participating in working group meetings please select the preferred time: weekdays evenings weekdays days weekends

*if submitting by e-mail, please type your name in the signature box

Print Name: Title:

Signature:* Date:

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Part 2. Tank and Operation Information

A. Instructions for Tank Information

This survey requests information on various tank process types. Three table types are provided (Table 1, Table 2, and Table 3). The tables you fill out will depend on your tank process types. Depending on your tank process, you may not be required to fill out all three tables. Please read the descriptions below to determine which tables to fill out.

Table 1. Fill out this table(s) for each tank(s) that conducts the following operations: hard plating, decorative plating, and/or chromic acid anodizing.

Table 2. Fill out this table(s) for each tank(s) that conduct other types of metal plating. Typical examples of this type of plating include copper and nickel plating conducted prior to chrome plating.

Table 3. Fill out this table(s) for each tank(s) that conduct other metal finishing/processing. Examples include:

• Electroless Plating: A chemical or auto-catalytic plating process that does not utilize external electrical power.• Sealing: A secondary operation for typically anodized parts with the goal of filling in surface pores of the coated part.

Examples of sealing solutions can be nickel and a potassium dichromate seal.• Passivation: Non-electrolytic process that adds a protective oxide layer.• Chem Film: A post anodizing operation (Iridite or Alodine are common names for Chem Film operation).• Stripping: Utilize either an acidic or caustic bath to remove a metal finish without the use of an electrical current.• Electropolishing: An electrochemical process that is similar to, but the reverse, of electroplating. The metal on the surface of

metal object being polished is removed one ion at a time.• Regeneration Tanks: Apparatuses or “Christmas trees” may accumulate plated material. Owners or operators may remove

this plated material by either chemical exposure or “reverse plating”.

Three example tables are provided beginning on Page 8 and four copies of each table are provided beginning on Page 10.

Information required to be filled out in tables 1, 2, and 3:

Tank Name/Identifier – Provide a tank name or identifier of your choice (e.g., Tank Hard Chrome, Tank 123, Tank ABC).

Surface Area – Provide the tank surface area in square feet (ft2).

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A. Instructions for Tank Information (cont’d.)

Bath Temperature – Indicate the bath temperature in degrees Fahrenheit.

Tank Process – Indicate the operation occurring in the tank (e.g. hard plating, decorative, and/or chromic acid anodizing). Check all that apply.

2017 Ampere-hours (amp-hrs) (only needed for Table 1) • Permitted: Specify the maximum operating amp-hrs permitted by local air district.• Actual: Indicate the actual amp-hrs operated in 2017.

Electrolytic (only needed for Table 2) – Indicate if the tank is electrolytic.

Tank Constituents - Indicate the tank constituents. Check all that apply.

Emission Controls – Check all of the emission controls that are being used for the tank

Agitation Method – Indicate the method that agitates the tank. Examples include: • Air Sparged (air injection into bath solution).• Mechanical (manually or automatic mixer or paddle).• Eductors: (water jet pumps, utilize kinetic energy to cause the flow of fluid).

When Agitation Occurs – Indicate when agitation occurs (e.g., pre-process, during process, after, etc.).

We have provided examples for completing Tables 1-3 below (pages 9-10)

*Note: Please complete the following table(s) for each tank(s). If you need additional pages, please make copies orcontact CARB staff listed on page 2

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TABLE 1 - Chrome Plating and Chromic Acid Anodizing Plating Tanks

Check “Yes” if you claim that Table(s) 1 contains confidential information Yes No Tank Name/Identifier: Chrome 1 Surface Area (ft²): 36 ft2 Bath Temp:(ºF): 130 Hex-Chrome Concentration (ppm): 10,000

Tank Process 2017 Ampere-hours

(for electrolytic tanks) Tank Constituent(s) Emission Controls used (check all that apply)

Agitation Method

When Agitation Occurs Permitted Actual

Hard Plating Hexavalent chrome Chemical fume supp. Air Sparged Pre-Process Decorative 50,000 35,000 Trivalent chrome Wetting agent Mechanical During Process Chromic Acid

Anodizing Other: Specify Mechanical fume supp. (e.g, polyballs)

Eductor None Foam blanket None Packed bed scrubber Composite mesh pads HEPA Ultra-low particulate air Encapsulated tank cover Mist eliminator Other: Specify None

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TABLE 2 - Other Metal Plating Tanks Check “Yes” if you claim that Table(s) 2 contains confidential information Yes No

Tank Name/Identifier: Nickel Plating 1 Surface Area (ft²): 49 ft2 Bath Temp:(ºF): 170

Tank Process Is Tank

Electrolytic? Tank Constituent(s) Emission Controls used (check all that apply)

Agitation Method

When Agitation Occurs

Metal Plating Yes No Nickel Chemical fume supp. Air Sparged Pre-Process Copper Wetting agent Mechanical During Process Zinc Mechanical fume supp. Eductor None Cadmium Foam blanket None Tin Packed bed scrubber Lead Composite mesh pads Sulfuric Acid HEPA Tin-Lead Ultra-low particulate air Other: Specify Encapsulated tank cover

Mist eliminator Other: Specify None

TABLE 3 – Other Metal Finishing/Processing Tanks Check “Yes” if you claim that Table(s) 3 contains confidential information Yes No

Tank name: Seal tank 1 Surface Area (ft²): 36 ft2 Bath Temp:(ºF): 200 Hex-Chrome Concentration (ppm): 1000

Tank Process Tank Constituent(s) Emission Controls used (check all that apply) Agitation Method When Agitation

Occurs

Sealing Hexavalent chrome Chemical fume supp. Air Sparged Pre-Process Passivation Nickel Wetting agent Mechanical During Process Chem Film Copper Mechanical fume supp. Eductor None Stripping Cadmium Foam blanket None Electropolishing Tin Packed bed scrubber Regeneration Tank Zinc Composite mesh pads Other: Specify Sulfuric Acid HEPA

Lead Ultra-low particulate air Tin-Lead Encapsulated tank cover Chromic acid Mist eliminator Other: Nitric acid Other: Specify

None

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B. Tank InformationTABLE 1 - Chrome Plating and Chromic Acid Anodizing Plating Tanks

Check “Yes” if you claim that Table(s) 1 contains confidential information Yes No Tank Name/Identifier: Surface Area (ft²): Bath Temp:(ºF): Hex-Chrome Concentration (ppm):



Agitation Method


Hard Plating Hexavalent chrome Chemical fume supp. Air Sparged Pre-Process Decorative Trivalent chrome Wetting agent Mechanical During Process Chromic Acid



Tank Name/Identifier: Surface Area (ft²): Bath Temp:(ºF): Hex-Chrome Concentration (ppm):



Agitation Method





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TABLE 1 - Chrome Plating and Chromic Acid Anodizing Plating Tanks (continued)




Agitation Method


Permitted Actual Hard Plating Hexavalent chrome Chemical fume supp. Air Sparged Pre-Process Decorative Trivalent chrome Wetting agent Mechanical During Process Chromic Acid






Agitation Method





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TABLE 2 - Other Metal Plating Tanks Check “Yes” if you claim that Table(s) 2 contains confidential information Yes No

Tank Name/Identifier: Surface Area (ft²): Bath Temp:(ºF):

Tank Process

Is Tank Electrolytic?

Tank Constituent(s) Emission Controls used (check all

that apply) Agitation Method


Metal Plating

Yes No Nickel Chemical fume supp. Air Sparged Pre-Process

Copper Wetting agent Mechanical During Process Zinc Mechanical fume supp. Eductor None Cadmium Foam blanket None Tin Packed bed scrubber Lead Composite mesh pads Sulfuric Acid HEPA Tin-Lead Ultra-low particulate air Other: Specify Encapsulated tank cover





Agitation Method




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TABLE 2 - Other Metal Plating Tanks (continued) Tank Name/Identifier: Surface Area (ft²): Bath Temp:(ºF):



Agitation Method







Agitation Method




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TABLE 3 – Other Metal Finishing/Processing Tanks Check “Yes” if you claim that Table(s) 3 contains confidential information Yes No



Occurs


Lead Ultra-low particulate air Tin-Lead Encapsulated tank cover Chromic Acid Mist eliminator Other: Specify Other: Specify

None



Occurs



None

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TABLE 3 – Other Metal Finishing/Processing Tanks (continued) Tank Name/Identifier: Surface Area (ft²): Bath Temp:(ºF): Hex-Chrome Concentration (ppm):


Occurs



None



Occurs



None

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C. Operation Information

1. Does your customer(s) require you to follow a Department of Defense (DOD) military standard (MIL-SPEC) related to yourchrome plating and/or chromic acid anodizing operations? Yes No

If yes, list all MIL-SPEC(s) that apply (e.g., MIL-A-8625).

2. If you answered yes to question 1, describe the MIL-SPEC requirements as they relate to chrome plating or chromic acidanodizing operations (e.g., process, temperature, air sparging, fume suppressants, durability, color etc.).

3. Does your customer(s) require you to follow a specification (non-DOD MIL-SPEC) related to your chrome plating and/orchromic acid anodizing operations? Yes No

If yes, list the specification(s) and the primes/OEMs that require the specification.

4. If you answered yes to question 3, describe the specification requirements as they relate to your chrome plating or chromicacid anodizing operations (e.g., process, temperature, air sparging, fume suppressants, durability, color, etc.).

5. Are any of your facility’s tanks located outside of a building? Yes No

If yes, indicate which tank(s) (list tank name/identifier as you provided in tank tables).

6. Is the plating line automatic, manual, or both?

Automatic Manual Both

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7. What is the method used to capture drag out during the transferring process (between tanks not immediately adjacent toeach other)?

Cart Rack Hoist Drip trays between tanks to minimize drag out Other, Specify:

8. Is a splash guard used when spraying down the parts? Yes No

9. What types of openings to the outside are associated with the building structure? Select all that apply.

Door(s) Fan(s) Roof vent(s) Window(s)

Other, Specify:

10. Are door(s), window(s), vent(s) open during operations? Yes No

11. Do you outsource any metal stripping, grinding, polishing and buffing processes? Yes No If so, which of these processes do you outsource to other businesses?

12. How often are HEPA filters changed (e.g., quarterly, biannually, etc)? Specify

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D. Cost Information

Estimated facility’s annual gross revenue for the past three calendar years (2015, 2016, and 2017)

2015 2016 2017

Check “Yes” if you claim that this cost information is confidential information Yes No

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PART 3. Buffing, Grinding, Polishing, and Compressed Air Operations

1. Does your facility conduct buffing, grinding or polishing of metal parts? If no, skip to question 5. Yes No

2. Does buffing, grinding, or polishing occur inside a building (e.g. a building has floors, walls, and roof)? Yes No

3. How are buffing, grinding, or polishing operations separated from the tank area (e.g., wall, plastic strip curtains, etc.)?

4. Is buffing, grinding, or polishing vented to an air pollution control system? Yes No If yes, what type of air pollution control system (e.g. baghouse)?

5. Does your facility use compressed air operations? Yes No If yes, specify the nearest process type (e.g., plating tank, grinding, buffing/polishing, etc.) and distance in feet to the compressed air operations. Process type: _____________ Distance:_______ft.

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PART 4. Housekeeping

1. What clean up method(s) are used at your facility to clean surfaces that accumulate or potentially accumulate chromium?Select as many that apply.

Hand wet mop Damp cloth HEPA vacuum Wet wash system Non-toxic chemical dust suppressant

Low pressure spray nozzle Other: Specify:

2. What is the housekeeping schedule (e.g. daily, weekly, etc.)? Please specify:

3. What materials are used for walkways and flooring around the tanks and throughout your facility? (e.g., wood, steel, concrete,carpet, etc.)? Please specify:

4. Describe your facility’s process for cleaning up spills.

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PART 5. Wastewater Processing

1. How does your facility manage wastewater? (check all that apply)

a. Discharge wastewater to a wastewater treatment plant

b. Closed loop rinse waster system

Briefly describe the system:

c. Treat wastewater onsite Briefly describe how the wastewater is treated (e.g. chromium treatment, pH adjustment):

d. Transfer wastewater offsite Briefly describe the process:

e. Other Briefly describe the system:

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PART 6. Chemical Fume Suppressant

Check “Yes” if you claim that Part 6 contains confidential information Yes No

Complete the following section if facility is using a chemical fume suppressant.

If facility does NOT use a chemical fume suppressant, skip to Part 7.

1. Name of non-PFOS fume suppressant

Fumetrol 21LF2 Macuplex STR NPFX HCA-8.4 Dicolloy CRFF

Other, Specify:_______________

2. Approximately, how long has your facility been using the non-PFOS fume suppressant? ___________

3. Approximately, how many gallons of non-PFOS fume suppressant does your facility use per year? _______gallons/year

4. What is the frequency and the amount of non-PFOS fume suppressant additions to the chrome plating/chromic acidanodizing tank bath?

5. At what surface tension is the chrome plating/chromic acid anodizing tank bath maintained? How often is it checked?

6. Does your facility measure surface tension with a stalagmometer or tensiometer? __________

7. Describe the surface conditions of the chrome plating/chromic acid anodizing tank bath (e.g., no foam, 2-inch layer of foam,> 2-inch layer of foam).

8. Has your facility experienced any problems with its parts (e.g., pitting) or other issues related to the use of the non-PFOSfume suppressant? If so, explain.

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PART 7. Building, Stack, and Plating Schedule Information

1. On average, how many days per week and hours per day does your facility typically conduct chrome plating or chromic acidanodizing operations? (e.g. 5 days per week /4 hours per day, 7 days per week/12 hours per day, etc.)

2. Specify the range of hours when chrome plating or chromic acid anodizing operations typically occurs?(e.g., between 6:00 am – 2:00 pm)

3. Is the operation vented to a stack? Yes No If no, skip to question 11.

4. What is the stack height (ground to exhaust point)? _______ ft

5. What is the stack diameter? ______ inches

6. What is the stack orientation? Horizontal Vertical

7. What is the stack exhaust temperature (°F)? Ambient Other, please describe:

8. Does the stack have a rain cap? Yes No Unknown

9. What is the exhaust flow rate (cubic feet per minute)? ________cfm

10. What are the dimensions of building (building on which the stack is located) L x W x H in feet? _______ ft

11. If you do NOT vent emissions through a stack, what are the dimensions of the building where you conduct plating operationsL x W x H in feet? ________ ft

PART 8. Additional or Proactive Control Measures

Check “Yes” if you claim that Part 8 contains confidential information Yes No

Please list and describe any notable measures your facility takes to minimize emissions. These may include monitoring techniques, housekeeping practices, altered production practices, or pollution prevention measures such as ion exchange and improved waste water treatment systems.

Do you have additional information to include?

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Provide a sketch/diagram of the tanks and the openings in the facility structure (Note: upload the facility’s sketch/diagram or send it by mail to the address listed on page 2). Estimate the distance from the tanks to the nearest structure openings. Indicate the tank name/identifier as you provided in the Part 2 tank tables. See example below.

EXAMPLE: Window

Door

Nickel Plating Tank 1

Chrome Plating Tank 1

Seal Tank 1

10 ft 20 ft

10 ft

PART 9. Facility Diagram

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Please provide a sketch/diagram or attachment here: (If mailing separately, please include facility name:) _______________

Thank you for taking the time to complete this Survey. Your participation is greatly appreciated. Your expertise, technical information, and opinions are instrumental for our agency to understand when determining how to best protect the environment, public health, and the economic stability of your business.

Click Button to Add Attachment

Instructions: • Click the button• Select the file to add• Click ok/open

(Note: attachment will not be visible)

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III. Confidential Information Submittal Form If you wish to designate any information contained in your survey data as CONFIDENTIAL INFORMATION, please provide the information requested below and return it with your completed survey form. In accordance with Title 17, California Code of Regulations (CCR), Sections 91000 to 91022, and the California Public Records Act (Government Code Section 6250 et seq.), the information that a company provides to the California Air Resources Board (CARB) may be released (1) to the public upon request, except trade secrets which are not emissions data or other information which is exempt from disclosure or the disclosure of which is prohibited by law, and 2) to the Federal Environmental Protection Agency, which protects trade secrets as provided in Section 114(c) of the Clean Air Act and amendments thereto (42 USC 7401 et seq.) and in federal regulation, and 3) to other public agencies provided that those agencies preserve the protections afforded information which is identified as a trade secret, or otherwise exempt from disclosure by law (Section 39660(e)). Trade secrets, as defined in Government Code 6254.7, are not public records and therefore will not be released to the public. However, the California Public Records Act states that air pollution emission data are always public records, even if the data comes within the definition of trade secrets. Even so, the information used to calculate air pollution data is not "emission data," and will not be released to the public if it is a trade secret. If any company believes that any of the information it may provide is a trade secret or otherwise exempt from disclosure under any provision of law, it must identify the confidential information as such at the time of submission to the CARB and must provide the name, address, and telephone number of the individual to be consulted. If the CARB receives a request for disclosure or seeks to disclose the data claimed to be confidential, the CARB may ask the company to provide documentation of its claim of trade secret or exemption at a later date. Data identified as confidential will not be disclosed unless the CARB determines, in accordance with the above referenced regulations, that the data do not qualify for a legal exemption from disclosure. The regulations establish substantial safeguards before any such disclosure. The applicable regulations are available from the Office of Administrative Law, or can be obtained by contacting Michelle Komlenic at (916) 322-3926. -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- - In accordance with the provisions of Title 17, California Code of Regulations, Sections 91000 to 91022, and the California Public Records Act (Government Code Sections 6250 et seq.) Enter Company Name: declares that information submitted in response to the California Air Resources Board's survey are confidential "trade secret" information, and requests that it be protected as such from public disclosure. Printed Name: Title: Signature: Date:

Mailing Address: City/State: Zip: Telephone Number: E-mail Address:

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CHROME PLATING AND CHROMIC ACID ANODIZING SURVEY · CHROME PLATING AND CHROMIC ACID ANODIZING SURVEY The California Air Resources Board (CARB) is working on amendments to the Hexavalent