From: Buonviri, Patricia (DEQ)

To: Goldsmith, Jason

Cc: Thompson, Tamera (DEQ)

Subject: RE: Chromium Electroplating RTR Data Request

Date: Friday, March 11, 2011 8:41:32 AM

Attachments: Cr Elecroplating Plant List_RTI - VA revised.xlsx

Electro Finishing permit.doc

standex NSR.docx

Trident NSR.docx

worldcolor tv permit.docx

Jason,

I've attached the information I have been able to gather in the short time frame. Copies of our TV

permits are available on our website at http://www.deq.virginia.gov/air/permitting/t5issued.htm. I am

attaching some documents that you may find useful. If there are specific stack tests that you would like

to have, I may be able to send them to you next week. If you have any questions, you can call me

Monday at (540) 872-7261 or on Tuesday at (804) 698-4016 or you can always email me. I won't be

available the rest of today.

Patricia Buonviri

Air Toxics Coordinator

Virginia Department of Environmental Quality

629 East Main Street

PO Box 1105

Richmond, VA 23218

(804) 698-4016

patricia.buonviri@deq.virginia.gov

From: Goldsmith, Jason [mailto:jgoldsmith@rti.org]

Sent: Tue 3/8/2011 9:40 AM

To: Buonviri, Patricia (DEQ)

Subject: RE: Chromium Electroplating RTR Data Request

Patty,

If the information is not readily available or easily accessible, we do not want to burden you with

too much extra work.  If need be, we can make assumptions using typical dimensions for tanks.

Thank you again for your assistance,

Jason Goldsmith

RTI International

Global Climate Change and Environmental Sciences

Air Quality Engineering Group

(202) 728-2469

jgoldsmith@rti.org

From: Buonviri, Patricia (DEQ) [mailto:Patricia.Buonviri@deq.virginia.gov] 

Sent: Tuesday, March 08, 2011 8:08 AM

To: Goldsmith, Jason

Subject: RE: Chromium Electroplating RTR Data Request
Jason,

How important are tank dimensions? I don't think I'll be able to get that information unless I call each

facility. I may not have time for that.

Patricia Buonviri

Air Toxics Coordinator

Virginia Department of Environmental Quality

629 East Main Street

PO Box 1105

Richmond, VA 23218

(804) 698-4016

patricia.buonviri@deq.virginia.gov

From: Goldsmith, Jason [mailto:jgoldsmith@rti.org]

Sent: Tue 3/1/2011 3:00 PM

To: Buonviri, Patricia (DEQ)

Subject: Chromium Electroplating RTR Data Request

Patty, 

As I explained during our telephone conversation, the U.S. Environmental Protection Agency (EPA),

is performing the residual risk and technology review of the National Emission Standards for

Hazardous Air Pollutants:  Hard and Decorative Chromium Electroplating and Chromium Anodizing

Tanks (Chromium Electroplating NESHAP).  Amendments to the NESHAP were proposed on October

21, 2010 (75 FR 65068), and EPA is under a court-ordered deadline to finalize the amendments by

June 30, 2011.  Several of comments received on the October 2010 proposal stated that EPA lacked

adequate data to fully assess the risk associated with emissions from chromium electroplating

sources; other commenters stated that EPA did not account for the facilities with the highest risk. 

In response to those comments, EPA is now trying to collect data on potentially high risk facilities. 

RTI International is assisting EPA in this effort by contacting several State agencies to request data

on the 5 to 10 facilities in those States that are likely to have the highest risk. 

Attached to this email is a spreadsheet which contains the entire list of facilities in Virginia, with

those that were identified as the highest risk highlighted.  If possible, could you or your staff

review the entire list and  update the plant list as necessary.

For the highlighted facilities, we would like to obtain additional information where available.  If

there are other facilities which you may believe to be the highest risk facilities due to either size or

location, then please provide information on those facilities as well.  Attached is a Word document

 that lists the specific types of data needed, and we would like to collect as many of the listed items

as possible for each facility.  The most critical data needs are: 

For each chromium electroplating or anodizing tank:

· Type of chromium electroplating process (hard, decorative, trivalent, anodizing)

· Surface dimensions (length and width)

· Rectifier capacity (amperes)
· Limits on rectifier operation (ampere-hours per year)

· Maximum permitted process operating hours (hours per year)

· Typical process operating hours (hours per year)

· Emission control method

· Emission test data (complete test report, if available)

In order to remodel risk for this source category and re-evaluate the regulatory options for

reducing risk to acceptable levels, while meeting the June 30, 2011 deadline, we would like to

obtain the requested information as soon as possible, and no later than March 11th, 2011.

If you have any questions about this request or would like to discuss any issues related to the

Chromium Electroplating NESHAP, you can contact Phil Mulrine with EPA's Office of Air Quality

Planning and Standards.  Phil can be reached by phone at:  919-541-5289, or by email at: 

mulrine.phil@epa.gov.

Thanks again for your help, and I look forward to talking to you soon.  Please let us know if you

have any questions and we appreciate your assistance with this effort.

Jason Goldsmith

RTI International

Global Climate Change and Environmental Sciences

Air Quality Engineering Group

(202) 728-2469

jgoldsmith@rti.org