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Metals Finishers – Technical Standard

In May, the Ministry of Environment and Climate Change (MOECC) posted on the Environmental Registry posted draft copies of the proposed Technical Standard for the Metal Finishers Industry. The technical standard covers hexavalent chromium, and nickel.

The proposed standard would apply only to facilities with NAICS code 332810 (Coating, Engraving, Heat Treating and Allied Activities).

As part of the environmental compliance options under O. Reg 419/05 facilities essentially have three options:

1) If the air quality limits of O. Reg 419/05 can be met, then applicants can then apply for an environmental compliance approval (ECA)
If the air quality limits of O. Reg 419/05 are exceed for one or more substances:

2) Apply for a technical standard (if one is available) to support the environmental compliance approval application (ECA).

3) Apply for a site-specific standard to support the environmental compliance approval (ECA) application

Since 2011, various manufacturers, and industry associations such as the Canadian Association for Surface Finishing (CASF) have approached the MOECC requesting to develop a technical standard under Local Air Quality Regulation O. Reg 419/05 for hexavalent chromium and nickel.

New, and more respective air quality standards for these contaminants come into effect in July 2016. With these new standards many facilities will be out of compliance, and unable to demonstrate compliance for an ECA. As part of the technical standard, the following sources have been identified for potential inclusion:
• Decorative chromium electroplating
• Hard chromium electroplating
• Chromium anodizing
• Chromium reverse etching
• Nickel plating
• Electroless nickel plating; and
• General ventilation

How are these substances created

Hexavalent chromium and nickel exists as charged ions inside the plating baths. Based on factors such as temperature, and surface tension these compounds will be generated as fume from the tanks, and be emitted into the facility fugitive or captured in direct ventilation systems.

Part of the proposed standard is specification of control technologies for hexavalent chromium generating processes, including the use of:
• air pollution control vehicle (such as a scrubber, or HEPA filter)
• fume suppressants,
• tank covers

For nickel emissions the following technologies have been specified for new or existing operations”
• air pollution control device (such as a scrubber or HEPA filter)
• wetting agent

An important point to note is the requirement to have a vertical and unimpeded discharge. This manner of discharge will maximize the dispersion from that stack. Often stacks are outfitted with rain caps to prevent rain from getting into the duct work. New stacks may now have to be double walled, or offset to meet the requirements. It’s important for facilities that are looking to modify equipment or processes, as this may mean that using existing stack locations simply won’t be possible.

Similar to the Operations and Maintenance terms and conditions of an Environmental Compliance Approval (ECA) facilities will also now be required to record operating parameters of the various sources, and pollution control equipment. For most pollution control equipment the required monitoring frequency is daily, however, for some new equipment like a packed bed scrubber, the requirements are continuous, meaning that instrumentation and computerized control systems will also need to be implemented. Detailed inspection and maintenance logs will also need to be prepared, and depending on the equipment at play, weekly inspections may be required.

Ventilation Program

The MOECC is also mandating that facilities appoint a ventilation coordinator, whose would have the responsibility of ensuring all the necessary documentation is in place. This would include:
• a description of all ventilation systems
• process flow diagrams (drawn to scale)

Ontario plating facilities would also be required to conduct a ventilation assessment report. Ventilation assessment reports are intended to ensure that the system is operating at optimal capture efficiency.
A ventilation assessment report would include:
• measured duct velocities
• static pressure measures in all branches
• volumetric flow rate calculations
• comparison of the total make-up air to exhaust air rates
• face velocity of hoods
• visual assessment of fugitive emissions
• exit velocity for each stack
• drawings showing orientation and configuration of each stack, and
• an assessment as to whether or not any part of the ventilation system is inadequate to capture fugitive dust emissions.

The above contains a couple of big ‘asks’ from the MOECC. First, process flow diagrams are drawn to scale. The reality is most facilities evolved over time, and having accurate drawings for all ducts and process equipment might be a challenge. For instance, some air pollution control equipment might predate electronic CAD packages, and records might either by absent or not easily transferable to include other equipment in the system. Also, the ventilation system seems to be overly constrained? Why so many measurements? Wouldn’t it be easier to require a professional engineer to certify whether or not the ventilation system is adequate to capture the identified contaminants? Making static pressure readings at every branch can surely have no value for most companies, and additionally, the reality is, most of these branches likely occur in areas where no safe access exists, or in the roofs where no sample ports are available. Additionally, most duct work within the industry was likely installed by contractors, and the availability of a suitable sample location in a laminar flow regime is scarce.

If you could like to know more about how Technical Standards, or how Rubidium can help feel free to give us a call or email: 905-635-4063 info@rb-enviro.com