HARD CHROME ELECTROPLATING MACT AMENDMENTS COMPLIANCE ASSURANCE 40 CFR PART 63, SUBPART N

1. HARD CHROME ELECTROPLATING MACT AMENDMENTS COMPLIANCE ASSURANCE40 CFR PART 63, SUBPART N

2. Compliance Dates • The final rule was published on January 25, 1995, • Existing major sources must comply with: • Emissions limitations (§63.342); • Work practices standard (§63.342); • Operation & Maintenance requirement (§63.342); • Performance test requirements (§63.344).

3. Compliance Dates (§63.343) (cont’d.) • New effected sources operating today, must comply with the regulatory requirements upon startup; • The effected sources must meet the notification and scheduling requirements in § 63.347; • Some of these notifications must be submitted before the effected source compliance date.

4. Compliance Dates (cont’d.) • The Subpart N Amendments were published July 19, 2004; • Compliance dates for amended operations at Subpart N facilities under the Final Rule; • Performance test required for amended Subpart N facilities.

5. Compliance Dates (cont’d.) • OSHA is required to promulgate the Permissible Exposure Limit (PEL) changes for hexavalent chrome by January 1, 2006; • Compliance with these changes may require amendments to Subpart N operations; • Performance tests may be required to establish compliance with Subpart N.

6. Operations & Maintenance Requirements (§63.342(f)) • Effected facilities must operate and maintain the sources, including air pollution control and monitoring equipment in a manner consistent with good air pollution practices that minimizes air emissions to the level required in Subpart N. • Effected sources must prepare and operate at all times according to a written operation and maintenance plan for each capture and collection control device controlling emissions subject to Subpart N.

7. O & M Requirements (cont’d.) • Each plan must contain the elements required in §63.342(f); • Equipment monthly inspections; • Operating limits for each capture system; • Appropriate operating limit parameters and design scope, i.e., control of multiple emissions sources; • Preventative maintenance plan for each control device including the manufacturer’s recommended maintenance instructions

8. O & M Requirements (cont’d.) • Corrective action for each pollution control device; • EXCEPT, during periods of startup, shutdown, and malfunction; • Maintain a log detailing the operation and maintenance of the process and emissions control equipment related to the initial performance test; and • The applicable operating limits for an effected source • Reporting Requirements (§63.347)

9. Initial Compliance Requirements for Amended Operations (§63.343) • A performance test must be conducted no later than 180 calendar days after the compliance date specific to an effected source; • For each work practice standard and operation and maintenance requirement that applies to an effected source where an initial performance test is not demonstrated, the effected source must demonstrate initial compliance no later than 30 calendar days after the specific compliance date for the effected source.

10. Initial Compliance (cont’d.) • Performance retest if facility decides to change the wet scrubber pressure drop options. • If facility opts to change to surface wetting agent fume suppressant.

11. Test Methods • Subpart N clearly defines the test methods and other procedures in §63.344 used to demonstrate initial compliance with the emissions limitations • The procedures in §63.344 are used to establish operating limits for: • Each capture system • Each wet scrubber • Alternative monitoring methods may be approve in accordance with §63.8(f).

12. Compliance with Work Practice Standards (§63.342(f)) • Demonstrate initial compliance with Subpart N; • The effected source has submitted a written Operations & Maintenance Plan; • The effected facility Will operate at all times according to that plan; • Malfunctions will be corrected as soon as practicable; • Monitoring, Recordkeeping and Reporting may be impacted by any malfunction.

13. Reports (§63.347) • Compliance reports required by specific due dates; • Ongoing compliance and exceedance reports required.

14. Emissions Exceedance Reports [§63.342] • Compare to Exceedance or Incident Reports • An exceedance report must be submitted immediately (if there was a an incident )

15. Title V Connect • USEPA is expected to exempt Subpart N sources from Title V; • Subpart N is a stand-alone federal standard; • State permits are typically required; Subpart N will be incorporated into State permit; • State construction permits will be required. • If a Subpart N source needs a Title V for a criteria pollutant status, the part 70 permit must also codify Subpart N as well.

16. Pollution Prevention Options • Enclosed chromium bath tank operations; • Fume suppressants; • Trivalent chromium bath operation.