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OAR Box 1158 

Prepped by Ryan Dugan 

Document Number: 

32) l-C-8 

Docket Number: 

A-88-02 

Printed 4/28/2008 2:34:12 PM Sheet 32 of 349 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 

3 F EB 1985 

Mr. Claude Theisen 

Vice President 

T & S Brass and Bronze Works 

Route 4 

Old Buncombe Road 

Travelers Rest, South Carolina 

Dear Mr. Theisen: 

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EPA AIR DOCKET 

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 plating. 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. 

A major element" of the program consists of locating and visiting a 

number of representative plants within each source category. From these 

visits, one or more plants will be selected as candidates for testing. 

The tests will be performed to quantify the amount and form (trivalent 

or hexavalent) of chromium discharged from chromium emitting facilities 

and air pollution control devices. 

This letter is to request a visit by Ms. Barb Duletsky and 

Mr. Charles Hester of Midwest Research Institute (MRI) to the T& S 

Brass and Bronze Works plant located in Travelers Rest, South Carolina, 

on March 5, 1985. They expect to arrive at your office about 11:00 a.m. 

This visit was discussed with you in a telephone conversation on 

February 15, 1985. 

We are interested in obtaining emission data, design data, 

operating data, and capital and operating costs for your process 

equipment and associated air pollution control equipment. Enclosure 1 

is a list of the general type of questions that we will be asking on our 

visit. 

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The authority for EPA's information gathering and source testing is 

included in Section 114 of the Clean Air Act (42 U.S.C. 7414). 

Enclosure 2 contains a summary of this authority. If you believe that 

disclosure of the information we request.would reveal a trade secret, 

you should clearly identify such information as discussed in the 

enclosure. Any information subsequently determined to constitute a 

trade secret will be protected 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. 

The EPA has contracted with MRI (Contract Number 68-02-3817) to 

obtain information pertinent to stationary source categories which emit 

chromium. 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. 

The following policies concerning liability should also be of 

interest to you: 

1. If a Federal employee is injured in the course of his 

employment, he has compensation coverage from the Government under the 

Federal Employees Compensation Act (5 U.S.C. 8108 et seq.); and 

2. If, due to the employee's negligence, property damage or 

personal injury to third parties occurs, the Federal Tort Claim Act 

(28 U.S.C. 1346) provides a means of fixing any liability upon the 

Federal Government. 

The Office of General Counsel has informed the Agency that a firm 

may not condition EPA's "right of entry" upon consent to a waiver of 

liability and has instructed employees not to sign such waivers. If you 

have any questions regarding this refusal, please contact Mr. Donnell L. 

Nantkes, Office of General Counsel, at (202) 382-5460. 

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If the date of this visit becomes impractical or you have any 

questions, please All Mr. Al Vervaert of EPA at (919) 541-5601, or 

Ms. Barb Duletsky of MRI at (919) 781-575Q. 

Sincerely, 

Stanley T. Cuffe, Chief 

Industrial Studies Branch 

Emission Standards and 

Engineering Division 

4 Enclosures 

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IDENTICAL LETTER SENT TO THE FOLLOWING ADDRESSEE: 

Mr. Lew Walker, Jr. A 

Executive Vice President •-./ 

Carolina Plating Company, Incorporated 

4412 White Horse Road 

Greenville, South Carolina 29611 

Variable information: Page 1, paragraph 3, line 2: "... to the 

Carolina Plating Company, Incorporated, plant located in Greenville, 

South Carolina, on March 5, 1985. They expect to arrive at your office 

about 3:00 p.m." 

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Enclosure 1 

ITEMS FOR DISCUSSION 

CHROMIUM PLATING 

1. General 

•. type and size of shop 

• type of chromium plating 

• products plated 

• number and size of tanks 

2. Chromium plating tank operating parameters 

• temperature 

• voltage 

• amperage 

• chromic acid concentration 

• plating time 

3. Air pollution control 

• degree of misting from the tanks 

• demisting agents used in the solution 

• type and rate of ventilation 

• type of control 

4. Availability of emission data 

• previous test results 

• feasibility of future testing 

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Docket No. A-88-02 

Subcategory I-C 

Enclosures 2,3, and 4 to this document are identical to 

enclosures 1,2, and 3 in docket item No. I-C-1. 

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