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OAR Box 1833 

Prepped by Keeia Richards 

Document Number: 

128) I-C-19 

Docket Number: 

A-88-02 

Printed 11/14/200811:01:32 AM Sheet 128 of 172 
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ILI OPY 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY A-88-0 2 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 X-C-\C\ 

WAV 2 1935 

Mr. Eugene Carpentier 

Plant Manager 

Stanley Tools Division 

425 Frank Street 

Fowlerville, Michigan 48836 

Dear Mr. Carpentier: 

As you may know, the United States Environmental Protection Agency 

(EPA) is considering adding chromium to the list of hazardous air pollutants 

under Section 112 of the Clean Air Act, as amended, August 1977. A 

preliminary assessment has identified 11 categories of stationary sources 

as potential emitters of significant quantities of chromium to the 

atmosphere. Included among these source categories is chromium electroplating. Because the preliminary assessment was based on limited data 

and available information, especially with respect to the quantities and 

forms of chromium actually emitted, EPA has undertaken a program to 

develop additional background information on all 11 source categories. 

This information will be used to determine the need for standards for 

each source category. 

We are requesting that Stanley Tools Division provide information 

on processes, emission levels, and emission control for its chromium 

electroplating operations in Fowlerville, Michigan. The specific 

information requested is itemized in Enclosure 1. This information, 

along with similar information from other companies, will be used to 

assess the significance of chromium emissions from the chromium electroplating industry. We are sensitive to the amount of labor required to 

respond to this request and have tried to limit it to information necessary 

to define the current status of emission control. Also, you may merely 

respond "not applicable" to questions that do not apply to your plant. 

The authority for EPA's information gathering is included in 

Section 114 of the Clean Air Act, as amended (42 U.S.C. 7414). Enclosure 2 

contains a summary of this authority. If you believe that disclosure of 

specific pieces of information you submit would reveal a trade secret, 

you should clearly identify such pieces of information. Please do not 

label an entire response "confidential" if only certain portions consist 

of trade secret information. Refer to Enclosure 2 for the information 

EPA may require, at a later time, to support your confidentiality claims. 

Any information determined to constitute a trade secret will be protected 

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under 18 U.S.C. 1905. If no claim of confidentiality accompanies the 

information when it is received by EPA, it may be made available to the 

public by EPA without further notice (40 CFR Part 2.203, September 1, 

1976). All emission data, however, will be available to the public. It 

will simplify handling procedures if you would separate specific items 

claimed to be confidential from the balance of the data. 

The EPA has contracted with Midwest Research Institute (MRI) (Contract 

No. 68-02-3817) to obtain information pertinent to the industry. Thus, 

as noted in Enclosure 3, MRI has been designated by EPA as an authorized 

representative of the Agency. Therefore, MRI has the rights discussed 

above and in Enclosure 2. As a designated representative of the Agency, 

MRI is subject to the provisions of 42 U.S.C. 7414(c), respecting 

confidentiality of methods or processes entitled to protection as trade 

secrets. 

Enclosure 4 summarizes Agency and Emission Standards and Engineering 

Division policies and procedures for handling privileged information and 

describes EPA contractor commitments and procedures for use of confidential 

materials. It is EPA's policy that compliance by an authorized representative with the requirements detailed in Enclosure 4 provides sufficient 

protection for the rights of submitters of privileged information. 

If you have any questions regarding this request or are unable to 

provide me with responses to the enclosed questions by June 5, 1985, 

please contact Mr. Al Vervaert or Mr. James Crowder, of the Industrial 

Studies Branch, at (919) 541-5601. 

Sincerely, 

Jack R. Farmer 

Director 

Emission Standards and 

Engineering Division 

4 Enclosures 

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IDENTICAL LETTER SENT TO THE FOLLOWING ADDRESSEES: 

1. Mr. Robert Ellis 

Environmental Manager 

Attwood Corporation 

1016 North Monroe Street 

Lowell, Michigan 49331 

Variable information: Page 1, paragraph 2, line 1: ".. . that 

Attwood Corporation provide . . ." Line 3: . . . operations in 

Lowell, Michigan." 

2. Mr. Walter W. Sembauer 

Senior Chemist 

Bendix Electrodynamics 

11600 Sherman Way 

North Hollywood, California 91605 

Variable information: Page 1, paragrap paragraph 2, linine e 1: ".. . that 

e . . ." Line 3:

 rt_— Bendix Electrodynamics provide . . ."Lin e 3: " . . . operations in 

North Hollywood, California." 

3. Mr. John McCullars 

Environmental Engineer 

Murray Ohio Manufacturing 

Company 

Hannon Drive 

Lawrenceburg, Tennessee 38464 

Variable information: Page 1, paragraph 2, line 1: ".. . that 

Murray Ohio Manufacturing Company provide . . .' Line 3: ".. . operations 

in Lawrenceburg, Tennessee." 

4. Dr. Ralph Grotelueschen 

Director of Safety, Environment, 

and Energy Management 

Deere and Company 

John Deere Road 

Moline, Illinois 61265 

Variable information: Page 1, paragraph 2, line 1: ".. . that 

Deere and Company provide . . . Line 3: " . . . operations in Moline, 

Illinois." 

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5. Mr. Charles Lent 

Plant Manager 

Delta Faucet Company 

State Route 46 West 

Greensburg, Indiana 47240 

Variable information: Page 1, paragraph 2, line 1: ".. . that 

Delta Faucet Company provide . . . Line 3: " . . . operations in 

Greensburg, Indiana." 

6. Ms. Jacki Savage 

Staff Specialist 

Chrysler Corporation 

CIMS 416-15-14 

Post Office Box 1919 

Detroit, Michigan 48288 

Variable information: Page 1, paragraph 2, line 1: ".. . that 

Chrysler Corporation provide . . .' Line 3: " . . . for all of its 

chromium electroplating operations." 

7. Mr. Austin Veldboom 

Plating Process Supervisor 

FCM Plastics Division of Plastics 

Technology, Incorporated 

2555 Oak Industrial Drive NE 

Grand Rapids, Michigan 49505 

Variable information: Page 1, paragraph 2, line 1: ".. . that 

FCM Plastics Division Corporation provide . . ." Line 3": ".. . operations 

in Grand Rapids, Michigan." 

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Enclosure 1 

INFORMATION REQUEST FORM 

CHROMIUM PLATING—CAPTIVE PLATER 

Please provide answers to the following questions. Attach drawings 

wherever appropriate. If you believe that any of the information 

requested 1s confidential, please submit this information on a separate 

sheet marked "CONFIDENTIAL." 

Name and address of plant: 

Name and title of respondent: 

Telephone number of respondent: 

Date: 

A. General 

1. Plant location (UTM coordinates or latitude/longitude): 

2. Age of plant: 

3. Hours of operation: h/d d/wk wk/yr 

4. Processes performed at the plant: 

5. Types of products or items that receive chromium plate: 

6. No. of chromium plating tanks at the plant: 

S 
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B. 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

11. 

12. 

13. 

14. 

15. 

16. 

17. 

2 

Chromium Plating Operation 

For each chromium plating tank, please provide the following 

information (cite typical values rather than ranges for operatinq and 

production parameters): 

Tank identification 

Manufacturer 

Date installed 

Type of platinq (e.q.. 

hard, decorative, 

etching, etc.) 

Automatic or manual dip 

Dimensions of tank 

(1 x w x d), ft 

Tank capacity, qal 

Freeboard (I.e., 

distance from surface 

of solution to top of 

tank), in. 

Substrate plated (e.g., 

plastic, brass, etc.) 

Concentration of chromic 

acid, oz/gal 

Chromic acid usaqe. 

lb/mo 

Catalyst(s) used 

Concentration of 

catayst(s), oz/gal 

Temperature of platinq 

solution, °F 

Operatinq voltaqe, 

volts 

Operatinq current. 

amperes 

Current density. 

amperes/ft plated 

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18. Surface area plated, 

ft /rack 

19. Thickness of chromium 

deposited, in. 

20. Plating time, min/rack 

21. Hours of operation, h/d; 

d/wk; wk/yr 

22. Percent of operating 

time electrodes are 

energized 

23. Production rate, ft2 

plated/yr 

24. Total ampere-hours for 

a typical year 

C. Emission Control System 

For the emission control system used on each chromium plating tank, 

please provide the following information: 

1. Tank identification 

(see Question B.l.) 

2. Demisting agent used 

a. Type (e.g., foam, 

plastic balls, 

etc.) 

b. Manufacturer 

c. Brand name 

d. Usage, lb/yr 

e. Estimated control 

efficiency, % 

f. Basis for estimate 

3. Emission capture system 

a. Manufacturer 

b. Model 

c. Type (e.g., side 

draft hoods, 

push-pull, etc.) 

d. Year of installation 

e. Size (1 x w) , ft 

f. Height above tank, 

1n. 

g. Percent of tank 

surface area 

covered by hood 

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h. Estimated capture 

efficiency, % 

i. Basis for estimate 

4. Emission control device 

a. Manufacturer 

b. Model 

c. Type (e.g., packedbed scrubber, etc.) 

d. Year of Installation 

e. Gas flow rate, scfm 

Actual 

Design 

f. Inlet gas temperature, °F 

g. Type of liquid used 

for scrubbing 

h. L1qu1d-to-gas ratio 

i. Gas pressure drop 

across system, 

in. H20 

j. Control efficiency, % 

Actual 

Design 

k. Destination of 

collected material 

D. Emissions 

For each chromium plating tank, please provide estimates for both 

controlled and uncontrolled emissions, citing the basis for each 

estimate. If the estimates are based on actual test data, provide copies 

of all applicable test reports. Also, please provide information on any 

existing State emission limitations with which your plant must comply. 

1. Tank identification 

(see Question B.l.) 

2. Uncontrolled emissions, lb/h 

Particulate matter 

Total chromium 

Hexavalent chromium 

Basis for estimates 

3. Controlled emissions, lb/h 

Particulate matter 

Total chromium 

Hexavalent chromium 

Basis for estimates 

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4. 

E. 

plal 

assc 

disc 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

F. 

prov 

1. 

2. 

3. 

5 

State emission limitations, lb/h 

Particulate matter 

Total chromium 

Hexavalent chromium 

Stack Parameters 

Please provide a plan view of the plant, identifying each chromium 

ting tank or Hn e and all stacks and other emission discharge points 

Dciated with the control devices listed in Section C. For each 

:harge point, please provide the following: 

Identification (as 

shown on plan view) 

Type (e.q., horizontal 

vent, vertical 

stack, etc.) 

Sources serviced 

Height above qround 

level, ft 

Inside diameter, 1n. 

Volumetric flow, acfm 

Gas temperature, °F 

Capital and Annualized Costs 

For the emission control system on each chromium plating tank, please 

nde the following cost information (Base year = ): 

Tank indentlfication 

(see Question B.l.) 

Capital costs, $ 

a. Control device 

b. Hood 

c. Fan 

d. Ductwork 

e. Stack 

f. Installation fee 

q. Total 

Annualized costs « 

a. Capital recovery, 

$/yr 

Interest rate, % 

Depreciation life. 

yrs 

b. Electricity. $/yr 

Unit cost. $/kWh 

c. Water. $/yr 

Unit cost. 

S/1,000 gal 

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d. Maintenance, $/yr 

Labor, man-h/yr 

Materials, $/yr 

e. Demisting agent, $/yr 

Unit cost, $/lb 

f. Chromic acid 

recovery, $/yr 

Quantity of chromic 

a d d recovered, 

lb/yr 

Unit value, $/lb 

q. Total 

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Docket No. A-88-02 

Subcategory I-C 

Enclosures 2, 3, and 4 of this document are 

identical to enclosures 1, 2, and 3 in docket item 

No. I-C-1. 

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