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OAR Box 1158 

Prepped by RyanDugan 

Document Number: 

47) l-C-23 

Docket Number: 

A-88-02 

Printed 4/28/2008 2:34:13 PM Sheet 47 of 349 
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A-88-02 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 

;PS5 

Mr. Tim Mathews 

General Electric Company 

3001 West Radio Drive 

Florence, South Carolina 29501 

Dear Mr. Mathews: 

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 

electro-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. 

We are requesting that General Electric Company provide information 

on processes, emission levels, and emission control for its facility in 

Florence, South Carolina. The specific information requested is itemized 

in Enclosure 1. This information, along with similar information from 

other companies, will be used to assess the significance of chromium 

emissions from the chromium electro-plating industry. We are sensitive 

to the amount of labor required to respond to this request and have 

tried to limit it to information necessary to define the current status 

of emission control. Also, you may merely respond "not applicable" to 

questions that do not apply to your plant. 

The authority for EPA's information gathering is included in 

Section 114 of the Clean Air Act, as amended (42 U.S.C. 7414). 

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

disclosure of specific pieces of information you submit would reveal a 

trade secret, you should clearly identify such pieces of information. 

Please do not label an entire response "confidential" if only certain 

portions consist of trade secret information. Refer to Enclosure 2 for 

the information EPA may require, at a later time, to support your 

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confidentiality claims. Any information 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. It will simplify handling procedures 

if you would separate specific items claimed to be confidential from the 

balance of the data. 

The EPA has contracted with Midwest Research Institute (MRI) 

(Contract No. 68-02-3817) to obtain information pertinent to the industry. 

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. 

If you have any questions regarding this request or are unable to 

provide me with responses to the enclosed questions by July 8, 1985, 

please contact Mr. Al Vervaert or Mr. James Crowder, of the Industrial 

Studies Branch, at (919) 541-5601. 

Sincerely, 

Jack R. Farmer 

Director 

Emission Standards and 

Engineering Division 

4 Enclosures 

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Enclosure 1 

NOT SUBJECT TC f; "•ENTSQfa * 

SECTION 3507. Pr'"" ' '•' ACT OFWW. 

INFORMATION REQUEST FORM 

CHROMIUM PLATING—CAPTIVE PLATER 

Please provide answers to the following questions. Attach drawings 

wherever appropriate. If you believe that any of the information 

requested 1s confidential, please submit this Information on a separate 

sheet marked "CONFIDENTIAL." 

Name and address of plant: 

Name and title of respondent: 

Telephone number of respondent: 

Date: 

A. General 

1. Plant location (UTM coordinates or latitude/longitude) 

2. Age of plant: 

3. Hours of operation: h/d d/wk wk/yr 

4. Processes performed at the plant: 

5. Types of products or items that receive chromium plate: 

6. No. of chromium plating tanks at the plant: 

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B. Chromium Plating Operation 

For each chromium plating tank, please provide the following 

information (dte typical values rather than ranges for operating and 

production parameters): 

1. Tank identification 

2. Manufacturer 

3. Date installed 

4. Type of plating (e.g., 

hard, decorative, 

etching, etc.) 

5. Automatic or manual dip 

6. Dimensions of tank 

(1 x w x d) , ft 

7. Tank capacity, gal 

8. Freeboard (i.e., 

distance from surface 

of solution to top of 

tank), 1n. 

9. Substrate plated (e.g., 

plastic, brass, etc.) 

10. Concentration of chromic 

add, oz/gal 

11. Chromic add usage, 

lb/mo 

12. Catalyst(s) used 

13. Concentration of 

catayst(s), oz/gal 

14. Temperature of plating 

solution, °F 

15. Operating voltage, 

volts 

16. Operating current, 

amperes 

17. Current density, 

amperes/ft plated 

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18. Surface area plated, 

ft /rack 

19. Thickness of chromium 

deposited, in. 

20. Plating time, m1n/rack 

21. Hours of operation, h/d; 

d/wk; wk/yr 

22. Percent of operating 

time electrodes are 

energized 

23. Production rate, ft2 

plated/yr 

24. Total ampere-hours for 

a typical year 

C. Emission Control System 

For the emission control system used on each chromium plating tank, 

please provide the following Information: 

1. Tank identification ' 

(see Question B.l.) 

2. Demisting agent used 

a. Type (e.g., foam, 

plastic balls, 

etc.) 

b. Manufacturer 

c. Brand name • 

d. Usage, lb/yr 

e. Estimated control 

efficiency, % 

f. Basis for estimate 

3. Emission capture system 

a. Manufacturer 

b. Model 

c. Type (e.g., side 

draft hoods, 

push-pull, etc.) 

d. Year of Installation 

e. Size (1 x w) , ft 

f. Height above tank, 

1n. 

g. Percent of tank 

surface area 

covered by hood 

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4. 

D. 

h. 

i. 

Em1 

a. 

b. 

c. 

d. 

e. 

f. 

g. 

h. 

1. 

j. 

k. 

Estimated capture 

efficiency, % 

Basis for estimate 

ssion control device 

Manufacturer 

Model 

Type (e.g., packedbed scrubber, etc.) 

Year of Installation 

Gas flow rate, scfm 

Actual 

Design 

Inlet gas temperature, °F 

Type of Hquid used 

for scrubbing 

L1qu1d-to-gas ratio 

Gas pressure drop 

across system, 

1n. H20 

Control efficiency, % 

Actual 

Design 

Destination of 

collected material 

Emissions 

For each chromium plating tank, please provide estimates for both 

controlled and uncontrolled emissions, citing the basis for each 

estimate. If the estimates are based on actual test data, provide copies 

of all applicable test reports. Also, please provide information on any 

existing State emission limitations with which your plant must comply. 

1. Tank identification 

(see Question B.l.) 

2. Uncontrolled emissions, lb/h 

Particulate matter 

Total chromium 

Hexavalent chromium 

8as1s for estimates 

3. Controlled emissions, lb/h 

Particulate matter 

Total chromium 

Hexavalent chromium " 

Basis for estimates 
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4. State emission limitations, lb/h 

Particulate matter 

Total chromium 

Hexavalent chromium 

E. Stack Parameters 

Please provide a plan view of the plant, Identifying each chromium 

plating tank or Hn e and all stacks and other emission discharge points 

associated with the control devices listed 1n Section C. For each 

discharge point, please provide the following: 

1. Identification (as 

shown on plan view) 

2. Type (e.g., horizontal '___ 

vent, vertical 

stack, etc.) 

3. Sources serviced • 

4. Height above ground • 

level, ft " 

5. Inside diameter, 1n. 

6. Volumetric flow, acfm • 

7. Gas temperature, °F 

F. Capital and Annualized Costs 

For the emission control system on each chromium plating tank, please 

provide the following cost Information (Base year = ): 

1. Tank 1ndent1f 1cat1on ' 

(see Question B.l.) 

2. Capital costs, $ 

a. Control device 

b. Hood 

c. Fan 

d. Ductwork 

e. Stack 

f. Installation fee 

g. Total 

3. Annualized costs t 

a. Capital recovery, 

$/yr 

Interest rate, % 

Depredation Ufe , 

yrs 

b. Electricity, $/yr 

Unit cost, $/kWh 

c. Water, $/yr 

Unit cost, 

$/l,000 gal 

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d. Maintenance, $/yr 

Labor, man-h/yr 

Materials, $/yr 

e. Demisting agent, $/yr 

Unit cost, $/lb 

f. Chromic add 

recovery, $/yr 

Quantity of chromic 

a dd recovered, 

lb/yr 

Unit value, $/lb 

g. Total 
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Docket No. A-88-02 

Subcategory I-C 

Enclosures 2, 3, and 4 of this document are 

identical to enclosures 1, 2, and 3 in docket item 

No. I-C-l. 

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