# DRAFT

Date: August 3, 2007

Subject: Recommendations on Emission Estimates for Chromium Electroplating Risk and Technology Review – Technical Support for the Metals, Minerals, & Energy Sectors EPA Contract No. EP-D-06-118; WA No. 1-11 RTI Project No. 0210426.001.011

From: Richard Marinshaw

To: Phil Mulrine EPA/SPPD/MMG (D243-05) U.S. Environmental Protection Agency Research Triangle Park, NC 27711

I. Introduction

This memorandum presents recommendations on revising the estimated emissions of chromium compounds for several facilities that are subject to National Emission Standards for

Chromium Emissions from Hard and Decora tive Chromium Electroplating and Chromium Anodizing Tanks (40 CFR 63, subpart N), hereafter referred to as the Chromium Electroplating NESHAP. Earlier this year, emissions from several chromi um electroplating and anodizing

facilities were modeled to assess the residual risk for the Chromium Electroplating Source Category. This memorandum focuses on a select group of plants for which the modeling indicated high risk.

The emission estimates used in the mode ling were taken from the National Emission Inventory (NEI) Database. The actual pollutant modeled varied among the plants. For most plants, the modeled pollutant was hexavalent ch romium. However, some plants were modeled for "chromium and compounds," some for "c hromium," and one plant was modeled for

"chromium trioxide."

The results of the risk assessment are presented in three documents: Risk and Technology Review–Phase II, Source Categor y Information Summary, Preliminary Draft, Chromic Acid Anodizing (June 2007); Risk and Technology Review – Phase II, Source Category Information Summary, Preliminary Draft, Deco rative Chromium Electroplating (June 2007); and Risk and Technology Review – Phase II, Source Category In formation Summary, Preliminary Draft, Hard Chromium Electroplating (June 2007).

II. Background

Section 112(f)(2) of the Clean Air Act (C AA) requires the Environmental Protection Agency (EPA) to assess the risk remaining (r esidual risk) after the application of maximum2

achievable control technology (MACT) standards under Section 112(d) of th e CAA. In response to the preliminary residual risk assessment of the Chromium Electroplating Source Category, RTI International (RTI) was asked to review the emissions estimates for several facilities that were indicated as high risk, and present recomme ndations on revising those emission estimates. Specifically, RTI reviewed the emission estimates for all plants for which the maximum individual lifetime cancer risk (MIR) was at le ast 10 per million, and for which RTI already had

information on file. RTI also tried to obtain ad ditional information for any plants with an MIR of at least 100 per million, and for which RTI did not have the data on file to estimate emissions. Finally, RTI identified any other of the modeled plants for which RTI had information on file indicating that the plant either was closed or no longer performed chromium electroplating or anodizing.

III. Summary of Results and Recommendations for Revised Emissions Estimates

The general approach used in this anal ysis was to present any available emission estimates developed either by the facility or regulatory agency; develop emission estimates based on the available design, operating, and emission te st data; and recommend the estimates that appear to be most representative of actual emissions. Emissions were estimated based on emission test data, if available. If emission test data were not available, estimates were made using the available design and operating data and conservative assumpti ons, which should result in overestimates for most plants. Annual emissi ons were estimated using the actual or typical operating hours presented in the plant's permit or permit applic ation. If actual or typical operating hours were unknown, it was assumed that the tank was operated continuously throughout the year (i.e., 8,760 hours per year).

The recommended emission rates are pr esented as chromium compounds, unless indicated otherwise (e.g., the f acility or State agency estimat ed emissions as hexavalent chromium). However, with one exception, the form of chromium used in chromium electroplating baths is hexavale nt chromium, and testing conduc ted during the development of the Chromium Electroplating NESHAP demonstrated that emissions are almost entirely in the form of hexavalent chromium. The only excepti on is for trivalent chromium baths, which are sometimes used in decorative chromium electroplating.

Table 1 summarizes the results of RTI's re view and presents revi sed emission estimates for several of the decorative chromium electropl ating plants that were included in the risk modeling; Table 2 presents the same information for several hard chromium electroplating plants. Details on the emission estimates for each of the subject facilities are provided in Attachment 1. Since the modeling did not indica te high cancer risk for any of the chromium anodizing plants included in the risk modeli ng, those emission data were not reviewed.

With a few exceptions, the NEI emission data used to model risk appear to be significantly higher than wh at would be expected for these type s of sources. An example is the Empire Hard Chrome -- Kostner Avenue Plant (NEIIL03161). The NEI indicates emissions of 395 pounds per year (lbs/yr) for this plant, wherea s as RTI estimated 31.2 lbs/yr. RTI's estimate is based on emissions at the emission limit, a nd therefore is likely to overestimate actual emissions. This plant can also be used as a be nchmark for hard chromium electroplating plants3

because it reportedly is one of, if not the, largest hard chromium electroplating plant in the U.S. in terms of production. Consequently, any es timate of emissions for a hard chromium electroplating plant that is signi ficantly greater than 30 lbs/yr s hould be scrutinized. Emissions from decorative chromium electropl ating plants should be significan tly lower than this level for two reasons: (1) electropl ating emissions are largely a function of the electrical current applied, and hard chromium electroplating generally uses much higher electrical current levels than does decorative chromium electroplating; and (2) deco rative chromium electroplating plants generally operate fewer chromium electroplating tanks th an the 12 tanks operated by the Empire Hard Chrome plant. Our calculations indicate that emissions for most decorative chromium electroplating plants ar e less than 2 lbs/yr.

One final note concerns the Norbrook Pla ting Inc. facility (NEI MIB6660), located in Warren, Michigan. The modeling results indicated an MIR of 6,000 per million for this facility. Only one other of the modeled plants had an MI R value this high. RTI currently does not have

the information needed to estimate emissions for th is plant. We have made several attempts to contact the State agency for inform ation, but have been unsuccessful.4Table 1. Summary of Emission Estimate Review for Decorative Chromium ElectroplatingNEISiteID Facility Name City State MIRModeledpollutantNEIemissions,(lbs/yr)Revisedemissions(lbs/yr)aCommentsNEISC0671254 AVM INC MARION SC Chromiumtrioxide1,299 1.76 No MIR because emissions reported as"chromium trioxide." Pollutant should bechromium compounds or hexavalentchromium.NEI49228 BERTEAU-LOWELLPLATING WORKSCHICAGO IL 300 Hexavalentchromium63.6 0.588NEICA0732913 CA PLATING SAN DIEGO CA Hexavalentchromium0.00730 0.0 Plant closed.NEI22524 CHROME CRAFT SACRAMENTO CA 100 Hexavalentchromium11.8 No basis for changing data, but NEIemissions are likely to be high.NEIMIA8830 CHROME CRAFT CORP HIGHLANDPARKMI 10 Hexavalentchromium3.00 No basis for changing data, but NEIemissions are likely to be high.NEI11893 DECO'PLATE MFGCOMPANYLAPEER MI 300 Hexavalentchromium919 1.27NEICO0129 DENVER METALFINISHINGDENVER CO 1,000 Chromium &compounds35.6 1.12 Plant operates hard and decorativechromium electroplating tanks; hard Cremissions: 0.000357 tpy; decorative Cremissions: 0.000202 tpy.NEI20872 KOTOFF & CO INC EL MONTE CA Hexavalentchromium0.126 0.0 Plant closed.NEI11509 MANUFACTURERSPLATING COMPANY,INCORPORATEDCLEVELAND OH 6,000 Chromium 910 1.59 Comprised of 0.672 lbs/yr of hexavalentchromium and 0.913 lbs/yr of trivalentchromium.NEIMIB6660 NORBROOK PLATING,INC.WARREN MI 6,000 Hexavalentchromium1,061 Waiting on additional information fromState agency.NEIIL0317010 P & H PLATING CO INC CHICAGO IL 1 Hexavalentchromium0.193 0.0 Plant closed.NEI2OH007477 QUALITY PLATINGCOMPANY,INCORPORATEDCLEVELAND OH 200 Hexavalentchromium95.2 0.160NEISC2506 SPARTAN INDUSTRIES PACOLET SC 10 Chromium &compounds1.73 No data on facility, but emissions appear tobe reasonable.NEI21339 STANDARD NICKELCHROMIUM PLATINGCO INCLOS ANGELES CA 100 Hexavalentchromium17.7 0.0 Plant closed.aEmissions estimated as chromium compounds unless otherwise indicated.5Table 2. Summary of Emission Estimate Review for Hard Chromium ElectroplatingNEISiteID Facility Name City State MIRModeledpollutantNEIemissions,(lbs/yr)Revisedemissions(lbs/yr)aCommentsNEIMIN6362 ARMORCLAD INC FARMINGTNHLSMI 20 Hexavalentchromium45.0 No basis for changing data, but NEIemissions are likely to be high.NEIIL0317128 CHROMIUMINDUSTRIES INCCHICAGO IL 80 Hexavalentchromium29.2 3.80NEI2OH008143 DIAMOND HARDCHROME,INCORPORATEDCLEVELAND OH 100 Chromium 19.4 1.80NEIIL0317425 DOVERINDUSTRIALCHROMECHICAGO IL 90 Hexavalentchromium20.7 4.76NEIIL0317476 ECONOMY PLATINGINCCHICAGO IL 200 Hexavalentchromium40.7 4.24NEIIL03161 EMPIRE HARDCHROMECHICAGO IL 900 Hexavalentchromium395 31.2NEIKY936 GENERAL ELECTRICCOMADISONVILLE KY 600 Hexavalentchromium502 0.0 No emissions; plant does not performchromium electroplatingNEIIL0310GBT GRAVURE PROCESSCOCHICAGO IL 20 Hexavalentchromium3.77 0.260NEIKS1030001 HALLMARK CARDS,INC. (SELECTPRODUCTS)LEAVENWORTH KS 200 Chromium 395 0.894NEINJNJ34427 INDUSTRIAL HARDCHROMIUM CO.NEWARK NJ 90 Chromium 11.9 No basis for changing data, but NEIemissions are likely to be high.NEI2OH001715 MASTER CHROMESERVICECLEVELAND OH 30 Chromium 2.02 No dataon facility, but emissions appear tobe reasonable.NEI52502 QUEBECOR PRINTING MT. MORRIS IL 20 Hexavalentchromium21.5 No basis for changing data, but NEIemissions are likely to be high; compare torevised estimate to Hallmark Cards.NEIWI1220499 SCOT INDUSTRIES MUSCODA WI 20 Hexavalentchromium8.71 0.240aEmissions estimated as chromium compounds unless otherwise indicated.Attachment 1.

Detailed Summary of Emission Estimate Review1

NEISiteID: NEISC0671254 Facility Name: AVM Inc.

Address: P.O. Box 729 Marion, SC 29571 Source category: Decorativ e Chromium Electroplating Pollutant: Chromium compounds NEI Emissions: 0.65 tpy (1,300 lbs/yr)

MIR: Not determined

Summary of Analysis :

The initial risk results indicated a hazard index of 7, but no cancer risk because the pollutant was

listed in the NEI as chro mium trioxide. Since the process is decorative chromium electroplating, the pollutant should be reported as either chromi um compounds or hexavalent chromium. Based

on an emission estimate obtained from the South Carolina Department of Environmental Control (SC DEHC), the potential annual emissions of chromium compounds from the facility's chromium electroplating operations are es timated to be 0.00088 tpy (1.76 lbs/yr).

Recommendation:

Use SC DEHC estimate of 0.00088 tpy (1.76 lbs/yr).

References:

1. South Carolina Department of Environmental Control. 2006. Engineering Calculation Sheet (Statement of Basis), AVM Industries, Pe rmit No. 1660-0220-CD. Bureau of Air Quality, Engineering Services Division. April 6.2

NEISiteID: NEI49228 Facility Name: Berteau-Lowell Plating Works

Address: 2318 W. Fullerton Avenue Chicago, IL 60647 Source category: Decorativ e Chromium Electroplating Pollutant: Chromium compounds NEI Emissions: 0.0318 tpy (63.6 lbs/yr) MIR: 300 per million

Summary of Analysis :

Emissions reported to NEI are based on Illinois EPA estimated emissions for 2005. In their 2005 Emission Inventory Report, the facility report ed emissions of chromium compounds to be 0.000294 tpy (0.588 lbs/yr). According to the pe rmit and other information provided by the Illinois EPA, the plant operates one "small" de corative chromium electr oplating tank. Based on data provided in the facility's permit applica tion, which indicates that the plant operates two decorative chromium electroplating tanks, RTI es timated actual emissions for two tanks to be 0.0000858 tpy (0.172 lbs/yr).

Recommendation:

Use facility estimate of 0.000294 tpy (0.588 lbs/yr).

References:

1. Illinois Environmental Protection Agency. 2005. DAPC Annual Emi ssion Inventory Report - 2005, Berteau-Lowell Plating Works, Inc., Fa cility ID No. 031600EDI. Division of Air

Pollution Control. December 13.

2. Illinois Environmental Protection Agency. 2004. Federally Enforceab le State Operation Permit – NESHAP Source, Berteau-Lowell Plati ng Works, Inc., Facility ID No. 031600EDI. Division of Air Pollution Control. September 28.

3. Berteau-Lowell Plating Works. (undated). Permit Application for Decorative Chrome Plating, Berteau-Lowell Plating Works, Inc., 232 0 West Fullerton Avenue, Chicago, Illinois.

Submitted to Illinois Environmental Protection Agency, Division of Air Pollution Control.

4. Memorandum, Marinshaw, R. and S. Burns, RT I International, to P. Mulrine, EPA/SPPD. 2005. Risk Modeling Input Data for Chi cago Chromium Electroplating Plants. September 28.3

NEISiteID: NEI22524 Facility Name: Chrome Craft

Address: 1819 23rd Street Sacramento, CA 95816 Source category: Decorativ e Chromium Electroplating Pollutant: Chromium compounds NEI Emissions: 0.00588 tpy (11.8 lbs/yr) MIR: 100 per million

Summary of Analysis :

No information was available for this facility. However, emissions of more than 4.0 lbs/yr year for a decorative chromium electroplating plant should be considered unusually high.

Recommendation:

Additional plant-specific data s hould be obtained and evaluated.4

NEISiteID: NEI11893 Facility name: Deco'Plate Manufacturing Company

Address: 395 DeMille Road Lapeer, MI 48446 Source category: Decorativ e Chromium Electroplating Pollutant: Chromium compounds NEI Emissions: 0.46 tpy (919 lbs/yr) MIR: 300 per million

Summary of Analysis:

The permit for the facility specifies an em ission limit for hexava lent chromium of 2.9 micrograms per cubic meter ( μ g/m 3 ). Based on an air toxics study submitted to the State agency, the exhaust flow rate for the chromium electroplating tank is 13, 300 actual cubic feet per minute (ACFM). Using this flow rate, and a ssuming that the electroplating tank was operated continuously (8,760 hr/yr), emissions of hexavale nt chromium at the emission limit would be 0.000633 tpy (1.27 lbs/yr).

Recommendation:

Use estimate of 0.000633 tpy (1.27 lbs/yr).

References:

1. Michigan Department of Environmental Qu ality. 1999. State of Michigan Renewable Operating Permit, Deco'Plate Manufacturing Company, Permit No. 199600451. Air Quality

Division. June 2.

2. Horizon Environmental Corporation. 2001. T echnical Support Document, Application for a Permit to Install Proposed Modification to an Existing Decorativ e Chromium Plating Operation, Lapeer, Michigan, for Dott Indus tries, Inc. -- Deco Plate Manufacturing, 395 DeMille Road, Lapeer, MI 48446. January 8.5

NEISiteID: NEICO0129 Facility name: Denver Metal Finishing

Address: 3100 East 43rd Avenue Denver, CO 80216 Source category: Decorativ e Chromium Electroplating Pollutant: Chromium compounds Source category: Decorativ e Chromium Electroplating NEI Emissions: 0.0178 tpy (35.6 lbs/yr) MIR: 1,000 per million

Summary of Analysis:

The plant submitted an ICR response for the Plating and Polishing industry, but the response

does not include information on their chromi um electroplating operation. The Colorado Department of Public Health and Environm ent (CO DPHE) was contacted on July 26, 2007 and provided an inspection report and stack test summary for the plant. Based on that information, the plant performs both decorative (one tank) and hard chromium electroplating (three tanks). Since typical operating hours were not known, RTI estimated emissions assuming continuous operation (8,760 hr/yr). Based on this assumpti on and the stack test data provided, combined

emissions from all three hard chromium elect roplating tanks are 0.000357 tpy (0.714 lbs/yr).

No test data were available for the decorative chromium electroplating tank. Assuming the tank was operated continuously and emitted at the emi ssion limit, annual emissions are estimated to be 0.000202 tpy (0.405 lb/yr). Total emissions for all tanks would be 0.000559 tpy (1.12 lbs/yr).

It should also be noted that the facility has indi cated to CO DPHE that they will be closing the Denver facility in 2007.

Recommendation:

Use the following estimates:

0.000357 tpy (0.714 lbs/yr) for hard chromium electroplating 0.000202 tpy (0.405 lb/yr) for decorative chromium electroplating 0.000559 tpy (1.12 lbs/yr) for total plant emissions.

References:

1. Colorado Department of Public Health a nd Environment. 2006. Air Pollution Control Compliance Inspection Summary Sheet, Denver Metal Finishing. July 26.

2. Facsimile from Joyce, Jackie, Colorado Depart ment of Public Health and Environment, to Richard Marinshaw, RTI International. 2007. Stack test summary and APEN determination, Denver Metal Finishing. July 26.6

NEISiteID: NEI11509 Facility name: Manufacturers Plating Company

Address: 1859 East 63rd Street Cleveland, OH 44103 Source category: Decorativ e Chromium Electroplating Pollutant: Chromium compounds Source category: Decorativ e Chromium Electroplating NEI Emissions: 0.455 tpy (910 lbs/yr) MIR: 6,000 per million

Summary of Analysis:

Based on information included in the operating pe rmit and additional information obtained from the Cleveland Department of Pub lic Health (DPH), this plant ope rates two decorative chromium electroplating tanks. One tank is controlled with a wetting agent fume suppressant and a composite mesh pad (CMP). The exhaust flow rate indicated in the permit application is 34,000 ACFM, which is unusually high for a single el ectroplating tank. Based on this flow rate

and the emission factor from AP-42 for decorativ e chromium electroplatin g tanks controlled with a wetting agent fume suppressant (the only emissi on factor in AP-42 for controlled decorative chromium electroplating), emissions are estimated to be 0.00109 tpy (2.18 lbs/yr). This value is likely to be an overestimate for two reasons: it is based on a concentratio n for an unrealistically high exhaust flow rate; and the emission factor for decorative chromium electroplating tank controlled with a wetting agent fume suppressa nt and a CMP should be lower than the AP-42 emission factor used. Using a flow rate of 10,500 ACFM, which represents the design flow rate this size of tank and provides a more realistic es timate of emissions, emissions from this tank are estimated to be 0.000336 tpy (0.672 lbs/yr).

The other chromium electroplating tank at this plant uses a trival ent chromium bath. That tank

also is controlled with a fu me suppressant. The Cleveland DPH has no information on the capacity of the rectifier for this tank. Since rectifier capacity is needed for estimating emissions, RTI assumed the rectifier capacity for the la rgest size decorative model electroplating tank developed for the Chromium Electroplating NESHAP . Using that value a nd other data provided by Cleveland DPH, emissions were estimated to be 0.000457 tpy (0.913 lbs/yr) of trivalent chromium. Because of the assumptions used, this es timate also is likely to be an overestimate of

actual emissions from this tank. Total emissions of chromium compounds from both tanks are estimated to be: 0.000793 tpy (1.59 lbs/yr) of chromium compounds.

Recommendation:

Use the following estimates:

0.000336 tpy (0.672 lbs/yr) of hexavalent chromium 0.000457 tpy (0.913 lbs/yr) of trivalent chromium 0.000793 tpy (1.59 lbs/yr) of chromium compounds.7

References:

1. Ohio Environmental Protection Agency. 1999. Title V Permit, Manufacturers Plating Company, Inc., Facility ID:13-18-00-0838. April 8.

2. Telecon. Dejanivoc, Z., Clev eland Department of Public H ealth, with R. Marinshaw, RTI

International. Information on chromium elect roplating operations at Manufacturers Plating Company, Cleveland, Ohio. August 2.

3. U.S. Environmental Protection Agency. 1996. Electroplating, Section 12.20 in Compilation of Air Pollutant Emission Factors, AP-42, Fift h Edition, Volume I: Stationary Point and Area Sources. July.8

NEISiteID: NEIMIB6660 Facility name: Norbrook Plating, Inc.

Address: 11400 Nine Mile Rd. Warren, MI 48089 Source category: Decorativ e Chromium Electroplating Pollutant: Chromium compounds Source category: Decorativ e Chromium Electroplating NEI Emissions: 0.53 tpy (1,060 lbs/yr) MIR: 6,000 per million

Summary of Analysis:

The only information readily available for this plant is the permit, which does not provide adequate information for estimating emissions. Telephone calls were made to the State agency and messages left on July 19, 25, and 30, 2007. A request for information was sent by email on July 30, 2007.

Recommendation:

Pending receipt of additional information from State agency.

References:

1. Ohio Environmental Protection Agency. 1999. Title V Permit, Manufacturers Plating Company, Inc., Facility ID :13-18-00-0838. April 8.9

NEISiteID: NEI2OH007477 Facility name: Quality Plating Company, Incorporated

Address: 1443 East 40th Street Cleveland, OH 44103 Source category: Decorativ e Chromium Electroplating Pollutant: Chromium compounds Source category: Decorativ e Chromium Electroplating NEI Emissions: 0.0476 tpy (95.2 lbs/yr) MIR: 200 per million

Summary of Analysis:

Based on information obtained from the Cleveland DPH, this facility operates one decorative chromium electroplating tank with a volume of 250 gallons. The cap acity of the rectifier was not provided. However, based on data from other fac ilities, the rectifier capacity for a 250-gallon decorative chromium electroplating tank is ty pically no more than 2,000 amps. Assuming the rectifier for this tank has a cap acity of 3,000 amps, which should re sult in an overestimate of emissions, using the operating hours reported, and assuming tank emissions were at the emission limit, annual emissions are estimated to be 0.0000798 tpy (0.160 lbs/yr).

Recommendation:

Use estimate of 0.0000798 tpy (0.160 lbs/yr).

References:

1. Cleveland Department of Public Health. 2001. Cleveland Local Air Agency Minor Source Inspection Report, Quality Plating Co., Inc. February 23.

2. Ohio Environmental Protection Agency. 1987. Application for a Permit to Operate an Air Contaminant Source, Quality Plating Co. Inc. July 4.

3. Memorandum, Marinshaw, R. and S. Burns, RT I International, to P. Mulrine, EPA/SPPD. 2005. Risk Modeling Input Data for Chi cago Chromium Electroplating Plants. September 28.10

NEISiteID: NEI21339 Facility name: Standard Nickel Chromium Plating Company, Inc.

Address: 811-819 East 62nd Street Los Angeles, CA 90001 Source category: Decorativ e Chromium Electroplating Pollutant: Chromium compounds Source category: Decorativ e Chromium Electroplating NEI Emissions: 0.00885 tpy (17.7 lbs/yr) MIR: 100 per million

Summary of Analysis:

In a letter, dated July 5, 2006 to Dr. Donna L ee Jones, EPA/SPPD, a representative for the company stated that the facility st opped all plating operations in 1999.

Recommendation:

Eliminate facility from further analysis for the source category.

References:

1. Letter from George Dulgarian, Standard Ni ckel-Chromium Plating Company, to Dr. Donna Lee Jones, EPA/SPPD. 2006. Facility stopped all plating operations in 1999. July 5.11

NEISiteID: NEIIL0317128 Facility name: Chromium Industries, Inc. Address: 4646 West Chicago Avenue Chicago, IL 60651 Source category: Hard Chromium Electroplating Pollutant: Chromium compounds NEI Emissions: 0.0146 tpy (29.2 lbs/yr) MIR: 80 per million

Summary of Analysis:

This plant operates nine hard chromium electro plating tanks, all of which are controlled with CMPs. Based on data provided in the facility 's permit application, RTI estimated chromium emissions at the emission limit for typical ope rating hours to be 0.00327 tpy (6.55 lbs/yr), and

for emissions at the emission limit for the ma ximum allowable operati ng hours to be 0.00467 tpy (9.35 lbs/yr). Using the emission factor in AP-42 for CMP control, actual emissions are estimated to be 0.00190 tpy (3.80 lbs/yr).

Recommendation:

Use estimate of 0.00190 tpy (3.80 lbs/yr).

References

1. Illinois Environmental Protection Agenc y. 1996. Operating Permit NESHAP Source, Chromium Industries, Inc., 4645 West Chicago Avenue, Chicago, Illinois. Division of Air Pollution Control. May 15.

2. Chromium Industries. 1994. Application for Smaller Source Permit Program, Chromium Industries, Inc., 4645 West Ch icago Avenue, Chicago, Illinoi s. Submitted to Illinois Environmental Protection Agency, Divisi on of Air Pollution Control. October 18.

3. Memorandum, Marinshaw, R. and S. Burns, RT I International, to P. Mulrine, EPA/SPPD. 2005. Risk Modeling Input Data for Chi cago Chromium Electroplating Plants. September 28.

4. U.S. Environmental Protection Agency. 1996. Electroplating, Section 12.20 in Compilation of Air Pollutant Emission Factors, AP-42, Fift h Edition, Volume I: Stationary Point and Area Sources. July.12

NEISiteID: NEI2OH008143 Facility name: Diamond Hard Chrome, Incorporated

Address: 6110 Grand Avenue Cleveland, OH 44104 Source category: Hard Chromium Electroplating Pollutant: Chromium compounds NEI Emissions: 0.0097 tpy (19.4 lbs/yr) MIR: 100 per million

Summary of Analysis:

The NEI data are based on an estimate of emi ssions calculated by the Cleveland DPH. The

emissions are based on a mass balance of estimated chromium usage (specifi cally, a loss of 4%), a control efficiency of 98%, and typical ope rating hours. The plant operates seven hard chromium electroplating tanks that are contro lled with three separate composite mesh padpacked bed scrubber (CMP-PBS) systems. Tank s 1, 2 and 3 are exhausted to one CMP-PBS; Tanks 3, 4, and 5 are exhausted to a second CMP- PBS; and Tank 7 is exhausted to the third CMP-PBS. Test reports were obtained for controlled emissions from Tanks 4, 5, and 6 combined, and for controlled emissions from Ta nk 7. Using the emission test results, RTI

estimated actual emissions to be 0.000535 t py (0.107 lbs/yr) for Tanks 4, 5, and 6; and 0.000123 tpy (0.246 lbs/yr) for Tank 7. Using data provided in the permit application for the plant, RTI estimated emissions at the emissi on limit for Tanks 1, 2, and 3 combined to be 0.000725 tpy (1.45 lbs/yr). Summing these up, total ac tual emissions for the plant are estimated to be 0.000900 tpy (1.80 lbs/yr).

Recommendation:

Use estimate of 0.000900 tpy (1.80 lbs/yr).

References

1. Cleveland Department of Public Health. 2001. Cleveland Local Air Agency Minor Source Inspection Report, Diamond Hard Chrome, Inc. April 19.

2. Envisage Environmental Incorporated. 1998. Source Evaluation Results, No. 2 Chrome Scrubber Exhaust, Diamond Hard Chrome Inc., on April 21, 1998. May 6.

3. Envisage Environmental Incorporated. 1999. Source Evaluation Results, Exhaust Stack of No. 3 Scrubber, Diamond Hard Chrome Inc., on November 10, 1999. November 19.

4. Diamond Hard Chrome, Inc. 1997. Applicat ion for a Permit to Install, Diamond Hard Chrome, Inc. Submitted to Ohio Environmental Protection Agency. December 18.13

NEISiteID: NEIIL0317425 Facility name: Dover Industrial Chrome Address: 2929 North Campbell Avenue Chicago, IL 60618-7903 Source category: Hard Chromium Electroplating Pollutant: Chromium compounds NEI Emissions: 0.0103 tpy (20.7 lbs/yr) MIR: 90 per million

Summary of Analysis:

Based on data provided in the facility's perm it application, RTI estimated chromium compound emissions at the emission limit for typical ope rating hours to be 0.00455 tpy (9.11 lbs/yr) and for the maximum allowable operating hours to be 0.0109 (21.9 lbs/yr). Based on emission rates determined from the plant's initial performance test and assuming the typical annual operating hours reported in the permit application for the f acility, actual emissions are estimated to be 0.00238 tpy (4.76 lbs/yr).

Recommendation:

Use estimate of 0.00238 tpy (4.76 lbs/yr).

References

1. Illinois Environmental Protection Agency. 2004. Lifetime Operating Permit – Hard Chrome Electroplating Operation NESHAP Source, D over Industrial Chrome, 2929 North Campbell, Chicago, Illinois. Division of Air Pollution Control. October 19.

2. Schrodt, A.G. 1995. Permit Renewal Applicati on. Letter and attachments from Ariel G. Schrodt, Dover Industrial Chrome, 2929 North Campbell, Chicago, Illinois. Submitted to Illinois Environmental Protection Agency, Di vision of Air Pollution Control. January 30.

3. Memorandum, Marinshaw, R. and S. Burns, RT I International, to P. Mulrine, EPA/SPPD. 2005. Risk Modeling Input Data for Chi cago Chromium Electroplating Plants. September 28.14

NEISiteID: NEIIL0317476 Facility name: Economy Plating, Inc.

Address: 2350 North Elston Avenue Chicago, IL 60614-2929 Source category: Hard Chromium Electroplating Pollutant: Chromium compounds NEI Emissions: 0.0203 tpy (40.7 lbs/yr) MIR: 200 per million

Summary of Analysis:

Based on data provided in the facility's permit a pplication, RTI estimated emissions of chromium compounds at the maximum allowable opera ting hours to be 0.00656 tpy (13.1 lbs/yr). Emissions based on typical operating hours could not be estimated because the permit application included only the maximum allowa ble operating hours. Based on emission rates determined from the plant's initial performance test and the maximum allowable operating hours,

actual emissions are estimated to be 0.00212 tpy (4.24 lbs/yr).

Recommendation:

Use estimate of 0.00212 tpy (4.24 lbs/yr).

References

1. Illinois Environmental Protection Agency. 1998. Operating Permit for Hard Chrome Electroplating Operation NESHAP Source, Economy Plating, Inc., 2350 North Elston, Chicago, Illinois. Division of Air Pollution Control. March 31.

2. Economy Plating. 1998. Application for Pe rmit, Economy Plating, Inc., 2350 North Elston, Chicago, Illinois. Submitted to Illinois Envi ronmental Protection Agency, Division of Air Pollution Control. January 9.

3. Memorandum, Marinshaw, R. and S. Burns, RT I International, to P. Mulrine, EPA/SPPD. 2005. Risk Modeling Input Data for Chi cago Chromium Electroplating Plants. September 28.15

NEISiteID: NEIIL03161 Facility name: Empire Hard Chrome

Address: 1615 Kostner Avenue Chicago, IL 60623 Source category: Hard Chromium Electroplating Pollutant: Chromium compounds NEI Emissions: 0.198 tpy (395 lbs/yr) MIR: 900 per million

Summary of Analysis:

Based on data provided in the facility's permit a pplication, RTI estimated emissions of chromium compounds at the emission limit for typical opera ting hours to be 0.0156 tpy (31.2 lbs/yr) and for the maximum allowable operating hours to be 0.0198 (39.7 lbs/yr).

Recommendation:

Use estimate of 0.0156 tpy (31.2 lbs/yr).

References

1. Illinois Environmental Protection Agency. 2003. Lifetime Operating Permit Hard Chrome Electroplating Operation – NESHAP Source, Empire Hard Chrome, Inc., 1615 South Kostner Avenue, Chicago, Illinoi s. Division of Air Pollution Control. February 18.

2. Illinois Environmental Protection Agenc y. 1996. Operating Permit Hard Chrome Electroplating Operation – NESHAP Source, Empire Hard Chrome, Inc., 1615 South Kostner Avenue, Chicago, Illi nois. Division of Air Pollu tion Control. March 21.

3. Empire Hard Chrome. 1995. Application for Permit, Empire Hard Chrome, Inc.,1615 South Kostner Avenue, Chicago, Illinois. Submitted to Illinois Environmental Protection Agency,

Division of Air Pollution Control. December 8.

4. Memorandum, Marinshaw, R. and S. Burns, RT I International, to P. Mulrine, EPA/SPPD. 2005. Risk Modeling Input Data for Chi cago Chromium Electroplating Plants. September 28.16

NEISiteID: NEIKY936 Facility name: General Electric Co.

Address: 3050 Nebo Road Madisonville, KY 42431 Source category: Hard Chromium Electroplating Pollutant: Chromium compounds NEI Emissions: 0.251 tpy (502 lbs/yr) MIR: 600 per million

Summary of Analysis:

Based on the response by General Electric Compa ny (GE) to the informa tion collection request (ICR) for the Plating and Polishing Area Source Category, the Madisonville facility does not perform any chromium electroplating. The only t ype of electroplating performed at the plant is platinum electroplating.

Recommendation:

Eliminate facility from further analysis for this source category.

References

1. Email and attachments from Meyers, S., Gene ral Electric Company, to Dr. Donna Lee Jones, EPS/SPPD. 2006. Response to the Informati on Collection Request for the Plating and Polishing Area Source Category for the Madisonville, Auburn, Burlington, Mebane, Beaumont, Charleston, Denver, Minden, Schenect ady, and Somersworth facilities. August 3.17

NEISiteID: NEIIL0310GBT Facility name: Gravure Process Co.

Address: 4179 West Belmont Avenue Chicago, IL 60641-4617 Source category: Hard Chromium Electroplating Pollutant: Chromium compounds NEI Emissions: 0.00189 tpy (3.77 lbs/yr) MIR: 20 per million

Summary of Analysis:

Based on data provided in the facility's permit a pplication, RTI estimated emissions of chromium compounds at the emission limit for typical ope rating hours to be 0.000790 tpy (1.58 lbs/yr) and for the maximum allowable operating hours to be 0.000846 (1.69 lbs/yr). Based on emission rates determined from the plant's initial perf ormance test and assuming the typical annual operating hours reported in the pe rmit application for the plant, actual emissions are estimated to be 0.000130 tpy (0.260 lbs/yr).

Recommendation:

Use estimate of 0.000130 tpy (0.260 lbs/yr).

References

1. Illinois Environmental Protection Agency. 2002. Lifetime Operating Permit – NESHAP Source, Gravure Process Comp any, 4179 West Belmont Avenue, Chicago, Illinois. Illinois EPA, Division of Air Pollution Control. February 13.

2. Gravure Process Company. 1997. Permit Application Information. Gravure Process Company, 4179 West Belmont Avenue, Chi cago, Illinois. Submitted to Illinois Environmental Protection Agency, Divisi on of Air Pollution Control. April 8.

3. Memorandum, Marinshaw, R. and S. Burns, RT I International, to P. Mulrine, EPA/SPPD. 2005. Risk Modeling Input Data for Chi cago Chromium Electroplating Plants. September 28.18

NEISiteID: NEIKS103001 Facility name: Hallmark Cards, Inc. (Select Products Facility)

Address: 4901 Select Products Drive Leavenworth, KS 66048 Source category: Hard Chromium Electroplating Pollutant: Chromium compounds NEI Emissions: 0.197 tpy (395 lbs/yr) MIR: 200 per million

Summary of Analysis:

The 2005 Emission Inventory Report for this plant reported chromium compound emissions from chromium electroplating to be 0.13 tpy (260 lbs/yr), based on uncontrolled emissions of 0.24 tpy (480 lbs/yr) and an overall control effici ency of 45 percent. The uncontrolled emission

rate was based on a mass balance of chromium consumed in the electr oplating process, but

details of the calculation we re not provided. Based on othe r information included in the Emission Inventory Report and additional inform ation provided by the Ka nsas Department of Health and Environment, RTI estimated annua l emissions of chromium compounds at the emission limit to be 0.000447 tpy (0.894 lbs/yr).

Recommendation:

Use estimate of 0.000447 tpy (0.894 lbs/yr).

References

1. Kansas Department of Health and Envir onment. 2006. 2005 Emissions Inventory and Fee Form for Class I Sources. Hallmark Cards, Inc., Source ID No. 1030013. May 17.

2. Kansas Department of Health and Envi ronment. 2003. Air Emission Source, Class I Operating Permit, Hallmark Cards, Inc., Source ID No. 1030013. February 25.

3. Email from Allen, R., Kansas Department of H ealth and Environment, to R. Marinshaw, RTI

International. 2007. Additional information on the chromium electroplating operation at the Hallmark Cards facility in L eavenworth, Kansas. August 1.19

NEISiteID: NEINJNJ34427 Facility name: Industrial Hard Chromium Co.

Address: 7 Rome Street Newark, NJ 71019 Pollutant: Chromium compounds Source category: Hard Chromium Electroplating NEI Emissions: 0.00595 tpy (11.9 lbs/yr) MIR: 90 per million

Summary of Analysis:

Based on information provided on the company's we bsite, the plant operates nine hard chromium electroplating tanks that range in volume from 185 to 1,250 gallons. Emissions from the tanks are controlled with CMPs. Depending on the re ctifier capacity and annual operating hours, the reported emission rate for the plant (11.9 lbs/yr ) is not unreasonable, although actual emissions are likely to be lower.

Recommendation:

Use estimate of 0.00595 tpy (11.9 lbs/yr).

References:

1. Company website: http://www.ih cco.com. Accessed July 26, 2007.20

NEISiteID: NEIOH001715 Facility name: Master Chrome Service

Address: 5709 Herman Avenue Cleveland, OH 44102 Pollutant: Chromium compounds Source category: Hard Chromium Electroplating NEI Emissions: 0.00101 tpy (2.02 lbs/yr) MIR: 30 per million

Summary of Analysis:

No information on this plant is on file. However, the emission estimate appears reasonable for a hard chromium electroplating facility.

Recommendation:

Use estimate of 0.00101 tpy (2.02 lbs/yr).

References:

None.21

NEISiteID: NEI52502 Facility name: Quebecor Printing Address: 404 N. Wesley Avenue Mt. Morris, IL 61054 Pollutant: Chromium compounds Source category: Hard Chromium Electroplating NEI Emissions: 0.0107 tpy (21.5 lbs/yr) MIR: 20 per million

Summary of Analysis:

No additional data was available, and none was obt ained for this facility. However, the reported emissions are likely to be overestimates. For co mparison purposes, the estimated emissions from chromium electroplating at the Hallmark Cards fa cility, another printing facility with a captive electroplating operation, ar e 0.00047 tpy (0.894 lbs/yr).

Recommendation:

Additional plant-specific data s hould be obtained and evaluated.

References:

1. Illinois Environmental Protection Agency. 2003. Title V Clean Air Act Permit and Title I Permit., Quebecor World, Mt, Morris, II, Inc. Division of Air Pollution Control.

November 17.22

NEISiteID: NEIWI220499 Facility name: Scot Industries

Address: 810 East Nebraska Street Muscoda, WI 53573 Pollutant: Chromium compounds Source category: Hard Chromium Electroplating NEI Emissions: 0.00435 tpy (8.71 lbs/yr) MIR: 20 per million

Summary of Analysis:

The Analysis, Preliminary Determination, and Dr aft Permit issued by the Wisconsin Department of Natural Resources indicates the total potential to emit for all electroplating tanks is 0.000120 tpy (0.240 lbs/yr) of total chromium and 0.000035 tpy (0.0700 lbs/yr) of hexavalent chromium. RTI estimated worst case emissions, assuming all tanks emitted at the emission limit and operated continuously (8,760 hrs/y r) to be 0.0150 tpy (30.0 lbs/yr).

Recommendation:

Use estimate of 0.000120 tpy (0.240 lbs/yr).

References:

1. Wisconsin Department of Natural Resources. 2005. Analysis, Preliminary Determination, and Draft Permit for the Renewal of Operation Permit Number 122049950-P02 for Scot Industries, Inc., Located at 810 Nebraska , Muscoda, Grant County, Wisconsin, on the Operations of Existing Chromium Plati ng, Honing, and Metal Cleaning. December 21.