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 AM
Cc: 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.us
Data 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 anodizing

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 Composite 

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/m3 average.

• Other Available Supporting Documents

o Emission inventory report

o Permit application

o Operating permit

o Process flow diagram or sketch of plant layout