Summary of the 2023 Chrome Plating ATCM
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Important Dates and Actions
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This document is intended for the owner or operator of any facility in California performing decorative chrome plating or functional chrome plating, which includes hard chrome plating and chromic acid anodizing. The purpose of this document is to provide information about the key requirements and incentive funding for the Airborne Toxic Control Measure (ATCM) for Chromium Electroplating and Chromic Acid Anodizing Operations (Chrome Plating ATCM). The Chrome Plating ATCM was amended in 2023 and became effective on January 1, 2024. The final regulation order for the ATCM is available on the Chrome Plating ATCM webpage and on the CARB Rulemaking webpage. Note that this document does not include all requirements; therefore, facility owners or operators should refer to the final regulation order to ensure they are complying with all regulatory requirements.
The key dates and requirements of the Chrome Plating ATCM are listed below.
All chrome plating facilities
Starting January 1, 2024:
- No person shall construct or operate a new chrome plating facility that uses hexavalent chromium in California (applies to decorative and functional chrome plating facilities).
- Owners or operators of existing chrome plating facilities may modify their facilities after January 1, 2024, if they do not exceed permitted throughput levels in place as of January 1, 2024, and as long as any modified or additional hexavalent chromium tanks meet all applicable requirements.
- Owners or operators of chrome plating facilities that use hexavalent chromium shall implement the applicable housekeeping practices to minimize fugitive emissions.
- Once available, owners or operators must take the CARB Compliance Assistance Training Course, which is required every two years and fulfills the environmental compliance training required by section 93102.5(b) of the ATCM. CARB staff will notify the owners or operators when the course is available in early 2024.
Environmental compliance training conducted by the South Coast Air Quality Management District on Rule 1469 shall fulfill the requirements of section 93102.5(b).
Decorative chrome plating facilities
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By July 1, 2024:
- Owners or operators of chrome plating facilities that use hexavalent chromium shall implement best management practices to minimize fugitive emissions.
By January 1, 2025:
- Owners or operators of decorative chrome plating facilities that choose to pursue the January 1, 2030, alternative phase out pathway shall notify their local air quality management district or air pollution control district (District) that they are choosing to pursue the January 1, 2030, phase out pathway.
By January 1, 2026:
- Owners or operators of decorative chrome plating facilities that choose to comply with the January 1, 2030, alternative phase out pathway must meet the building enclosure requirements for Tier I tanks, Tier II tanks, Tier III tanks, and buffing, grinding, and polishing operations specified in section 93102.4(d) of the ATCM.
By January 1, 2027:
- Owners or operators of decorative chrome plating facilities that choose to comply with the January 1, 2027, phase out pathway, instead of the alternative phase out pathway, must stop using hexavalent chromium for the purpose of decorative chrome plating unless the District grants an extension (up to one year). By January 1, 2030:
- Owners or operators of decorative chrome plating facilities that choose to comply with the January 1, 2030 alternative phase out pathway must stop using hexavalent chromium for the purpose of decorative chrome plating unless the District grants an extension (up to one year).
Functional chrome plating facilities
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By July 1, 2024:
- Owners or operators of functional chrome plating facilities shall control hexavalent chromium emissions from Tier II tank(s) by utilizing a tank cover, mechanical fume suppressant, or other method approved by the District. Alternatively, they can comply with the applicable emission limit using an add-on air pollution control device (see the final regulation order for the tank tier definitions).
- Owners or operators of functional chrome plating facilities shall cover the entire surface area of Tier III tank(s) until the add-on air pollution control device has been installed and meets the applicable emission limits as required by the Chrome Plating ATCM. Owners or operators of functional chrome plating facilities that use hexavalent chromium shall implement best management practices to minimize fugitive emissions.
By January 1, 2026:
- Owners or operators of functional chrome plating facilities must meet the following requirements:
- Building enclosure requirements for Tier I tanks, Tier II tanks, Tier III tanks, and buffing, grinding, and polishing operations specified in section 93102.4(d) of the ATCM.
- New emission limits for all Tier III tanks, including chrome plating tanks, that contain hexavalent chromium as measured downstream of any add-on air pollution control device.
- Chrome plating tanks must meet an emission limit of 0.00075 mg/amp-hr of hexavalent chromium.
- Tier III tanks that are not chrome plating tanks must meet the emission limitations specified in section 93102.4(f) of the ATCM.
- Conduct an initial source test on Tier III tank(s) to determine compliance with hexavalent chromium emission limits and continue to conduct ongoing source tests every 2 calendar years.
By January 1, 2032
- CARB staff must complete the first technology review on alternatives to hexavalent chromium in functional chrome plating.
By January 1, 2036
- CARB staff must complete the second technology review on alternatives to hexavalent chromium for functional chrome plating.
By January 1, 2039
- Owners or operators may no longer use hexavalent chromium for the purpose of functional chrome plating.
Based on the results of the technology reviews, CARB staff may recommend amendments to the phase out dates for Board consideration.
Incentive funding for conversion
Facility owners may take advantage of incentive funding included as part of the Budget Act of 2023, AB 102 (Chapter 38, Statutes of 2023). As part of this, the legislature appropriated $10 million to transition away from the use of hexavalent chromium in chrome plating operations, including supporting small businesses that convert to trivalent chromium or an equally health protective alternative. These funds can be used to provide incentives for small businesses to transition away from hexavalent chromium, grow customer awareness and acceptance of trivalent chromium plating products, and fund demonstration projects that further alternative technologies. These funds will be available until June 2026, with a final expenditure deadline of June 2028. In addition, AB 617 (Chapter 136, Statutes of 2017) Community Air Protection (CAP) grants are available to assist with the transition to alternative technologies and are applicable to chrome plating facilities. Grants are available for the conversion of hexavalent chromium plating systems to trivalent chromium or an equally health protective alternative. Facilities that choose to transition to alternatives after 2027 may still be eligible for funding, but funding will be contingent on availability of grant money. CARB staff will notify the facility owners when the grant applications are available.