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 3 rd 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 QualityPlanning 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