From: Pitts, Tony
To: Hancy, Cindy Wang
Cc: Evans, Craig ; Kohli, Baldev ; Gross, Stephen (DEP) Subject: FW: Chromium Electroplating Information Needed
Date: Monday, February 28, 2011 1:58:00 PM
Attachments: DEP Cr Electroplating Data Needed.docx

Cindy,

Attached is the information received from Garrod Hydraulics

.
Tony

Tony A. Pitts | Air Quality Program Specialist Division of Permits | Air Toxics and Risk Assessments Department of Environmental Protection Rachel Carson State Office Building 400 Market Street | Harrisburg, PA 17101 Phone: 717.772.3364 | Fax: 717.772.2303 www.depweb.state.pa.us

-----Original Message----- From: Wesley Garrod [mailto:Wes@garrod.com] Sent: Monday, February 28, 2011 1:55 PM To: Pitts, Tony Subject: RE: Chromium Electroplating Information Needed

Tony, Please find attached answers to the information that you have requested. I am sorry so late and short answer but I have been very busy and wanted to get this out to you today.

Wes

Wesley E. Garrod
President & CEO

Garrod Hydraulics, Inc.
1050 Locust Point Road York, PA 17406

Phone: (717) 767-6429

Fax: (717) 767-9360
Cell: (717) 324-1137
e-mail: Wes@Garrod.com

From: Pitts, Tony [mailto:tpitts@state.pa.us] Sent: Tuesday, February 15, 2011 10:13 AMCc: Evans, Craig; Kohli, Baldev; Gross, Stephen (DEP) Subject: Chromium Electroplating Information Needed

Dear Sir/Madam, 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. The attached file 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)

We would like to obtain the requested information as soon as possible, please fill-in the attached form and return it to me no later than the end of February 2011. If you should have any questions, please feel free to contact me at 717-772-3364. Sincerely, Tony A. Pitts

Tony A. Pitts | Air Quality Program Specialist Division of Permits | Air Toxics and Risk Assessments Department of Environmental Protection Rachel Carson State Office Building 400 Market Street | Harrisburg, PA 17101 Phone: 717.772.3364 | Fax: 717.772.2303 www.depweb.state.pa.usData Needed on Chromium Electroplating and Anodizing Facilities

• Facility Data

o Name

– Garrod Hydraulics, Inc.

o Location

– 1050 Locust Point Road York, PA 17406

o Number of employees

- 35

o Type of electroplating facility (i.e., job shop, captive operation)

– Captive operation and Job shop

o Hours of operation

– 24 hours/day

o Annual revenue

– $1M Chrome Plating, $3.5M Total Business

• Process Type(s)

• Hard chromium electroplating

o Decorative chromium electroplating

o Trivalent chromium electroplating

o Chromium anodiz ing

o Other electroplating

o Other co

- located processes subject to NESHAP

• Tank Design and Operation

o Dimensions

– Tank# 1 = 60”X60”X84”, Tank#’s 2&3 = 36”X48”X288”

o Rectifier capacity

– Tank # 1 = 20 KA, Tank # 2&3 = 15 KA

o Annual hours of operation

o Permitted

– 8,760 Hours per year

o Actual

– Approx 5,000 Hours per year (estimated)

• Emission Control Technology

o Type of control method or control device

– Dry Impingement Composite Mesh Pad

o Exhaust system design (hood type/location, exhaust flow rate)

– Push/Pull Comp osite Mesh Pad Hoods, Tank#1 = 10,550 ACFM Tank #2&3 = 2@3,000 = 6,000 ACFM

o Control device operating parameters (e.g., bath surface tension)

– Less than +/

- 2 in Water Gage Pressure Drop Variation Across Scrubber.

• Emission Test Data

o Complete test report (if available) Tank#1 = 0.00565 mg/dscm average, Tank #2 &3 = 0.0015 mg/m 3 average.

• Other Available Supporting Documents

o Emission inventory report

o Permit application

o Operating permit

o Process flow diagram or sketch of plant layout