From: Gerry Pade

To: Hancy, Cindy Wang

Cc: Stella Nehen

Subject: RE: Cr Electroplating Data Request - US EPA

Date: Friday, February 11, 2011 2:13:44 PM

Attachments: 10029.pdf

10923.pdf

11979.pdf

14079.pdf

15000.pdf

15153.pdf

15199.pdf

16009.pdf

16088.pdf

16098.pdf

16328.pdf

18499.pdf

18660.pdf

20086.pdf

21177.pdf

21340.pdf

Cindy Hancy

RTI International

Dear Ms. Hancy,

Per your request, I’ve attached the registration file listings for our local chrome plating and

anodizing facilities. As I recall, the facilities performing hard chrome plating are Hytek Finishes,

Asko Processing, Pacific Propeller, Repair Technology, Hydraulic Repair & Design, and the US Navy

Puget Sound Naval Shipyard. The facilities performing decorative chrome plating are Mastercraft

Metal Finishing, Electrofinishing, Queen City Plating, Electro Forming Systems, Art Brass Plating, and

Silver Horde Fishing Supplies. The facilities performing chromic acid anodizing are Hytek Finishes,

Asko Processing, Protective Coatings, Pacific Propeller, Skills, the US Navy Puget Sound Naval

Shipyard, and the US Navy Naval Undersea Warfare Center.

All of the hard chrome plating tanks were required to have control equipment and to verify

compliance with the applicable emission limit (0.01, 0.015, or 0.03 mg/m3). A couple decorative

and anodizing tanks also utilize controls but most just use mist suppressants/foam blankets and

comply with the surface tension limit (45 dyne/cm). To obtain copies of the stack test reports and

Notice of Construction application folders, you’ll need to contact our Records Administrator, Stella

Nehen, at (206) 689-4011 or stellan@pscleanair.org.

Gerry Pade

Puget Sound Clean Air Agency

1904 3rd Ave, Suite 105

Seattle, WA 98101

(206) 689-4065

gerryp@pscleanair.org

“Working together for clean air”

 o_
_/ > _

(*)\(*)

From: Hancy, Cindy Wang [mailto:chancy@rti.org] 

Sent: Friday, February 11, 2011 9:31 AM

To: Gerry Pade

Subject: Cr Electroplating Data Request - US EPA

Gerry,

Thanks for speaking with me today. As I explained in our 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 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 is a file that lists the specific types of data needed, 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)

· Any updates to Cr. Electroplating facilities listed in the attachment (plant closings, etc.)

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 the end of February 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.

Cindy Wang Hancy

RTI International

P.O. Box 12194

Research Triangle Park, NC 27709

Phone: (919) 541-6623

Fax: (919) 316-3420