Commonwealth of Pennsylvania

Environmental Protection

April 29, 1998

Subject: Source Test Review

CMS Gilbreth Packaging Systems, Inc.

Bristol Township, Bucks County

To: Orlando Vasquez

Air Pollution Control Engineer

Southeast Regional Of fice

From: Robert Small

Air Pollution Control Engineer

Division of Source Testing and Monitoring

Bureau of Air Quality

Through: L. Blaine DeHaven

Chief

Division of Source Testing and Monitoring

Bureau of Air Quality

Timothy R. Brooks

Chief

Source Testing Section

Division of Source Testing and Monitoring

Bureau of Air Quality

CMS Gilbreth Packaging Systems, Inc. operates two (small & large) chromium electroplating

lines at the aforementioned location. Rotogravure printing cylinders are immer sed into chromic

acid baths until properly electroplated, rinsed off and dried.

The small plating tank has a 1,000

- amp rectifier and uses a wetting agent fume suppressant to

control the emissions. The emissions from the chrome plating tank are then discharged to the

atmosphere through a 14

- inch inside diameter stack.

The large plating tank has a 2,500

- amp rectifier and uses a composite mesh pad 4

- stage chrome

mist eliminator (fume scrubber) to control the emissions. The first three stages consists of

co mposite mesh pads (CMPs) and stage 4 is a water washdown of each pad. The emissions from

the scrubber are then discharged to the atmosphere through a 14

- inch inside diameter stack.Data File

CMS Gilbreth Packaging Systems

Bristol Township, Bucks County 2 April 29, 1998

On February 2

- 3, 1998, personnel from Avogadro Environmental Corporation conducted

chromium emission testing in the tanks exhaust stacks utilizing EPA Method 306 and analyzed

the samples using inductively coupled argon plasma emission spectrometry (ICAP). This test

program was conducted to demonstrate compliance with small and large plating tank NESHAP

MACT standard of 0.03 and 0.015 mg/dscm, respectively, and establish the pressure drop across

the system. The tests were conducted in accordance with acceptable sampling practices and the

conditions of an approved test protocol and are acceptable to the Department.

The following data was extracted from the test report:

Chromium Emission Summary for Small Plating Tank

Test Date 02/02/98 02/02/98 02/03/98

Test Run Number 1 2 3

Rated Rectifier Amperage

(amperage

- hour) 1,0 00

Rectifier Amperage during testing

(amperage

- hour) 550 562.5 600

Stalagmometer, (seconds)

Surface Tension, (dynes/cm) 39.5

43.5 40

43 38.5

44.5

Volumetric Flow Rate, (dscfm) 1,500 1,600 1,600

Cr Emission Concentration, (mg/dscm) 0.0166 0.0094 0.0096

Allowable Cr Emission Concentration, (mg/dscm) 0.03

Chromium Emission Summary for Large Plating Tank

Test Date 02/02/98 02/02/98 02/03/98

Test Run Number 1 2 3

Rated Rectifier Amperage

(amperage

- hour) 2,500

Rectifier Amperage during testing

(a mperage

- hour) 1150 1150 1150

Total Pressure Drop during testing (in H 2 O) 2.7 2.7 2.7

Volumetric Flow Rate, (dscfm) 3,100 3,300 3,400

Cr Emission Concentration, (mg/dscm) 0.0121 0.0185 0.00645

Allowable Cr Emission Concentration, (mg/dscm) 0.015Data File

CMS Gilbreth Packaging Systems

Bristol Township, Bucks County 3 April 29, 1998

cc: Ract Operating Permit No. 09

- 0037

Reading File

- Source Testing Section

Data File

- Stack Testing

Compliance & Enforcement

- Scott Kepner

Division of Permits

EPA/TRB