Chromium Electroplating, Chromium Anodizing and Reverse Etching Regulations: frequently asked questions
Question 1: I have decided to use a point source control method as my control option and I have indicated this to Environment and Climate Change Canada. I understand that by doing this, I now have 30 months, from the date that subsection 4(2) of the regulations came into force, to comply with performing a release test to meet the emission limit as indicated in subsection 4(1)(b). However, if during this interval of 30 months I decide to install one (or more) new tanks, which are also connected to my control device and which increases the tank surface area by more than 25%, am I required to conduct a stack test within 75 days of completing this addition?
Answer: Yes, if you add one or more tanks to increase your surface area by more than 25%, you are required under subsection 5(3) to perform a release test within 75 days of completing the installation.
Question 2: What is meant by "representative operating conditions" as this term relates to a release test?
Answer: "Representative operating conditions", as defined in the regulations, refer to conditions under which the required electrical output of the rectifier may be obtained for the purposes of performing the release test in accordance with section 5 of the regulations. The electrical output of the rectifier is to be the average of the previous 30 days' rectifier electrical output before the release test is performed. The 30 days are considered operating days; and do not include days when the rectifier is not used, such as weekends, statutory holidays or facility shutdowns.
Question 3: Our chromium electroplating tanks are kept warm when not in use. Does keeping a tank warm for more than 24 consecutive hours constitute "use" of a tank?
Answer: No, a tank is considered to be "in use" only if there is an electrical current flowing from the rectifier to the tank for the purpose of electroplating, anodizing or reverse etching.
Question 4: What is considered to be a "release to the environment" and what is considered to be a "likelihood of a release into the environment"? What is the difference between these two types of release?
Answer: An example of an actual release into the environment would be a release test with a result greater than the limit prescribed in paragraph 4(1)(b) of the regulations.
In the case of a likelihood of release into the environment, an example would be observing control device equipment anomalies while carrying out an inspection which could be expected to lead to a likelihood of release.
Question 5: Do these regulations address effluent releases to the environment?
Answer: No. These regulations address releases to air only.
Question 6: What is meant to be included in the 50 kg or more of chromium trioxide used per calendar year?
Answer: The use of 50 kg/year refers to the total amount of chromium trioxide in the tank or tanks at your facility plus the amount of chromium trioxide you add to each tank during the calendar year.
Question 7: Are there any provincial, territorial or municipal regulations related to releases of hexavalent chromium from the chromium electroplating sector?
Answer: You should contact your provincial Ministry of the Environment and municipal authorities for information on provincial/territorial or municipal regulations, and their requirements that may be applicable to your operations.
Question 8: What are the requirements for mandatory reporting to the National Pollutant Release Inventory (NPRI)?
Answer: Facilities that are subject to the Chromium Electroplating, Chromium Anodizing and Reverse Etching Regulations are required to report releases, disposals, and transfers for recycling of hexavalent chromium (and its compounds), regardless of the number of employees and regardless of the 50 kg NPRI threshold. Please visit the NPRI website for further information.
Question 9: I have two tanks connected to my control device. One tank is for chromium plating and the other tank is also for chromium plating but at the moment, due to economic conditions, is not used. Is the unused tank considered to be dilution air for the purposes of the release test if the ventilation from the unused tank is not closed off?
Answer: Yes. Ventilation air from plating tanks that are not in use, and which are connected to the same ventilation system used for chromium tanks that are in use, is considered to be dilution air for the purposes of the release test. In this case, the unused tank(s) is to be closed off from the ventilation system for the duration of the release test. The Regulations provide a definition of "dilution air".
Question 10: I am a chromium anodizer and I use a point source control device. My anodizing cycle time is only 40 minutes and I do only three anodizing cycles per week. How can I get "three 2 hour runs" that are required for the release test?
Answer: As a chromium anodizer, you may have to adapt your anodizing cycle times by either accumulating the parts which you anodize or by using "dummy parts" in order to give you sufficient anodizing time for the three two-hour runs required by the release test.
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