# DRAFT

DATE: August 16, 2010

SUBJECT: Section 112(d)(6) Technology Review for Chromium Electroplating NESHAP Emission Standards Technical Suppor t and Post Promulgation Activities EPA Contract No. EP-D-06-118; EPA Work Assignment No. 4-6 RTI Project No. 0210426.004.006

FROM: Richard Marinshaw

TO: Phil Mulrine, EPA/OAQPS/SPPD/MMG

The purpose of this memorandum is to presen t the results of a review of available information on developments in practices, processe s, and control technol ogies that apply to chromium electroplating, and specifically to s ources subject to the national emission standards for hazardous air pollutants (NESHAP) for Hard and Decorative Chromium Electroplating and for Chromium Anodizing Tanks (40 CFR 63, subpart N). This analysis is part of the U.S. Environmental Protection Agency’s (EPA’s) review efforts in a ccordance with se ction 112(d)(6) of the Clean Air Act (CAA). Section I of th is memorandum provides background information on the requirements of section 112(d)(6) of the CA A, the chromium electroplating source category, and the requirements of the Chromium Electropl ating NESHAP. Section II discusses the review of information on developments in practices, pr ocesses, and control t echnologies that have occurred since the original de velopment of this NESHAP.

I. Background/Purpose

A. Requirements of Section 112(d)(6) of the CAA

Section 112 of the CAA requires EPA to es tablish technology-based standards for sources of hazardous air pollutants (HAP). These technology-based standards are often referred to as maximum achievable control technology, or MACT, standards. Section 112 also contains provisions requiring EPA to revis it these standards. Specifica lly, paragraph 112(d)(6) section
states:

(6) REVIEW AND REVISION. – The Admini strator shall review, and revise as necessary (taking into acc ount developments in practi ces, processes, and control technologies), emission standards promulgated under this section no less often than every 8 years.

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For the purpose of this technology review, a “d evelopment” was considered to be any of the following:

• Add-on control technology or other equipment that was not identified and considered during the development of the NESHAP;

• Improvements in add-on control technology or other equipment that were not identified and considered during NESHAP development th at could result in significant additional HAP emissions reductions;

• Work practice or operational procedure that was not identified a nd considered during NESHAP development; and

• Process change or pollution prev ention alternative that could be broadly applied that was not identified and consid ered during the development of the NESHAP.

B. Description of Source Category and NESHAP Requirements

Electroplating is the process of applying a metallic coating to a surface by passing an electric current through an electrol yte that is in contact with the surface. Electroplating typically is performed in a tank containing th e electrolytic solution or bath, and the part or surface that is to be plated is immersed in the solution while an electric current is a pplied. A wide range of metals are electroplated on a commercial sc ale, with the most common including cadmium, chromium, copper, gold, lead, nickel, silver, tin, and zinc. The Chromium Electroplating NESHAP applies only to those processes that us e chromic acid in an electrolytic cell to deposit chromium metal or to form an oxide film on a surface, part, or product. Specifically, the NESHAP covers three types of processes: hard chromium el ectroplating, decorative chromium electroplating, and ch romium anodizing.

In hard chromium electroplat ing, a relatively thick layer of chromium is deposited directly on a base metal (usually steel) to provide a surface with wear resistance, a low coefficient of friction, hardness, and corro sion resistance. In decorative chromium electroplating, the base material ge nerally is plated with a layer of nickel followed by a relatively thin layer of chromium to provide a bright su rface with wear and ta rnish resistance. In chromium anodizing, also referred to as chromic aci d anodizing, chromic acid is used to form an oxide layer on aluminum to provide corrosion resist ance. Chromium anodizing is used primarily on aircraft parts and architectur al structures that are subjec t to high stress and corrosive conditions. Plating opera tions range in size from small shops , with one or two small tanks that are operated only a few hours per week, to large s hops, with several large tanks that are operated continuously.

During electroplating and anodizing opera tions, hydrogen and oxygen evolve on the outside of submerged parts or on anodes or cath odes. As the gas bubbles rise to the surface of the electroplating bath, they burst , creating emissions in the form of a fine mist. Air sparging (mixing of tank bath) also can re sult in emissions from the bursti ng of air bubbles at the surface of the plating tank liquid. The bursting of ai r bubbles at the tank surface is the mechanism for emissions from chromium electroplating.

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The principal techniques used to control em issions from chromium electroplating and anodizing tanks can be categorized as either add- on control devices or fume suppressants. Addon controls require the tank to be equipped w ith a ventilation system, consisting of a hood, ductwork, and exhaust fan, to capture emissions a nd direct the emissions stream to the control device or stack. The most common add-on c ontrol devices for chro mium electroplating operations are mist eliminators and wet scrubbers. Fume suppressants, which are used in the electroplating tank, can be used regardless of whether or not the tank is equipped with a ventilation system. Fume suppr essants reduce emissions by either lowering the surface tension of the plating bath or by creating a cover on the bath that inhibits the formation of mists.

The Chromium Electroplating NESHAP, wh ich was promulgated on January 25, 1995 (60 FR 4948) regulates chromium emissions fr om new and existing hard and decorative chromium electroplating and chromium anodizing tanks at major and area sources. To comply with the NESHAP, owners and operators of a ffected sources can eith er meet a chromium emissions concentration limit, or an electroplat ing bath surface tension limit. When first promulgated, the surface tension limit was an opti on for decorative chromium electroplating and for chromium anodizing, but not for hard chromi um electroplating. The NESHAP also specifies work practice standards, initial performance testin g, ongoing compliance monitoring, recordkeeping, and repo rting requirements.

Amendments to the Chromium Electropla ting NESHAP were promulgated on July 19, 2004 (69 FR 42885). The amendments extended the surface tension limit to hard chromium electroplating tanks – un der the original NESHAP, the surface tension limit option applied only to decorative chromium electr oplating and chromium anodizing tanks. The amendments also revised the surface tension limit when measured w ith a tensiometer; established a procedure for determining an alternate emission limit for hard chromium electroplating tanks equipped with enclosing hoods; revised definitions for chromi um electroplating and chromium anodizing tanks; and revised the monitoring requirements fo r a specific type of control system.

II. Practices, Processes, and Control T echnologies for Chromium Electroplating

A. Control Technologies Considered for NESHAP

Table 1 summarizes the practices, processes, and control technologi es considered during the development of the Chromium Electroplati ng NESHAP. The emission limits developed for hard chromium electroplating tanks were based on the levels of chromi um emissions control achieved using composite mesh pads; for decorative chromium electroplating and chromium anodizing tanks, the emission limits were based on the use of wetting agent fume suppressants (WAFS) for controlling emissions.

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Table 1. Summary of Controls Considered in Development of NESHAP a 

### General Category Technology Examples Add-on control Mist eliminator Composite mesh pad Mesh pad mist eliminator Fiber bed mist eliminator Chevron blade mist eliminator Wet scrubber Single or double packed bed scrubber Fan separator packed bed scrubber Centrifugal flow scrubber Fume suppressant Chemical Wetti ng agent fume suppressant (WAFS) Foam blanket Physical Plastic balls Other floating media

a 

### Reference 1.

B. Technology Developments Sin ce Promulgation of NESHAP

Since the NESHAP was promulgated in 1995, th ere have been several developments in the methods for controlling emissions from chromium electroplating tank. The following paragraphs describe these developments.

WAFS for Hard Chromium Electroplating

When the NESHAP was promulgated, using a WAFS without an add-on control device was not considered to be a viable option for meeting the emission limits for hard chromium electroplating tanks. However, based on recommendations made by the Common Sense Initiative (CSI) Metal Finishing Subcommittee and research conducted by EPA’s Office and 6Research and Development (ORD), it was concl uded that compliance with the emission limits can be achieved when a WAFS is used to reduce the surface tension below certain levels. This development was addressed in the 2004 amendments to the NESHAP.

Instrumental Differences in Surface Tension Measurements

The research performed by ORD also showed differences in electr oplating bath surface tension, depending on the type of instrument used ; measurements made using a stalagmometer in the range of the compliance value of 45 dynes pe r centimeter (dynes/cm) were typically about 10 dynes/cm higher than measurements made using a tensiometer. To account for this difference a provision was included in the 2004 amendments specifying 35 dynes/cm as the compliance level when a tensiometer is used to measure surface tension.

Enclosing Tank Hoods

A significant development in electroplating ta nk design occurred with the introduction of state-of-the-art plating tanks that feature enclosing hoods that comp letely cover the surface of the plating tank. The covered tank design allows for effective capture and ventilation at substantially lower ventilati on rates than otherwise encount ered with more conventional

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hooding. However, because the NESHAP emission limits are in the format of an emission concentration standard, it was ve ry difficult for some owners and operators to meet the emission limits. This problem was addressed in the 2004 amendments by including a provision for an alternative mass rate emission limit for these sources.

Emission Elimination Devices

Another development in controlling emissions from chromium electroplating tanks was the introduction of the emission elimination device ( EED), which is also referred to as a Merlin cover. This device consists of a tank cover that includes a porous membrane, which allows gases to escape, but captures droplets and mist emana ting from the electroplating tank. The EED has not gained wide acceptance, largely because it ofte n is not practical to cover the electroplating tank while plating is underway. Although the NES HAP does not specifically address the use of EEDs, §63.343(d) of the rule allows owners or operators of affected tanks to apply for case-bycase approval. For this reason, a nd the fact that these devices are not widely used, it is not recommended that the NESHAP be amended to address EED’s.

HEPA Filters

A high efficiency particulate air (HEPA) filte r is an air filtering device that contains a mat of randomly-arranged fibers specifically designed to remove at least 99.97 percent of airborne particles that are 0.3 micrometers or la rger in diameter. Although HEPA filters had been on the market for decades, they were not considered as a practical control method for electroplating tank emissions wh en the NESHAP was developed. The fine mesh of a HEPA filter would quickly clog up if subjected to chromium electroplating emissions, and there were several other types of mist eliminator technolog ies that had been proven to be effective for electroplating emissions. However, in the past de cade, facilities in Califo rnia have increasingly used HEPA filters to meet the emission limits of the state's Airborne Toxic Control Measure (ATCM) for Chromium Plating and Chromic Acid Anodizing F acilities. In October 2007, the California Air Resources Board (CARB) amended the ATCM to further tighten emission limits and to require HEPA f ilters on all new chromium electroplating and anodizing tanks. In these applications, HEPA filters act as a second stage of control, with the first stage generally consisting of a mesh pad mist el iminator or other device that first removes all of the large particles prior to the HEPA filter.

As part of this technology review, HEPA filters have been cons idered as a possible control option for sources subject to the Chromium Electroplating NESHAP. An analysis of the emissions reductions and annualized control costs has been perf ormed and is addressed in a separate memorandum, Emissions Reductions and Cost Effectiveness of HEPA Filters for Chromium Electroplating Sources.

CARB ATCM

As mentioned in the previously, CARB am ended their Chromium Electroplating ATCM in October 2007. The amendments made several significant changes to the rule, including more stringent emission limits, the requirement to install HEPA filters on new chromium

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electroplating tanks, rest rictions on the location of new ch romium electroplat ing facilities, housekeeping procedures for reducing fugitive emissions of chromium-laden dust, and procedures for using a stalagmometer for measur ing electroplating bath surface tension. A more detailed list of the major changes to the ATCM is included in Attachment 1.

After considering the change s to, and current requirements of, the ATCM, the decision was made to propose the following as a result of this technology review:

• Amending the Chromium Electroplating NESHAP to incorporate housekeeping procedures, and

• Amending Method 306B to include proce dures for using stalagmometers for measuring surface tension.

In both cases, the proposed procedures are based on the requirements speci fied in the ATCM.The proposed housekeeping procedures would help to minimize fugitive emissions of chromiumladen dust, and the proposed procedures for stalagmometers would help to ensure that the surface tension limits specified in the NESHAP are bein g maintained. As noted previously, the costs and emissions reductions associated with requ iring HEPA filters on chromium electroplating tanks also were evaluated.

PFOS-based Fume Suppressants

Wetting agent fume suppressants are used in most decorative chromium electroplating and chromium anodizing tanks and in many hard chromium electroplating tanks for emission control. Historically, the most effective types of WAFS have been based on perfluorooctane sulfonic acid (PFOS). These compounds are pa rt of a family of chemical compounds categorized as long-chain perfl uorinated chemicals (PFCs). As noted in EPA’s Long-Chain Perfluorinated Chemicals Action Plan, these compounds have persistent, bioaccumulative, and toxic (PBT) characteristics and are a part icular concern for children’s health. 2 

### Although it has not been demonstrated that these compounds cau se adverse effects to humans, studies have shown significant adverse effects to laboratory animals and wildlife. As a result, EPA intends to address the potential risks from this family of compounds by 2012 under the Toxic Substances Control Act.

The non-PFOS fume suppressants currently av ailable can generally be classified as anionic fluorinated surfactants. These com pounds contain six fluorinat ed carbons that cannot break down or decompose to PFOS. In addi tion, none of the components present in these compounds at concentrations equal to or greater than 0.1 percent ar e listed as carcinogens by the International Agency for Research on Ca ncer, the Occupational Safety and Health Administration, National Toxicol ogy Program, or the American Conference of Governmental Industrial Hygienists as a carcinogen. 3



### In view of the increasing concern over the presence of long-chain PFCs in the environment, and the fact that other types of WAFS are effective in chromium electroplating operations and are available at a reasonable cost, a phase-out of PFOS-based WAFS is being proposed as a result of this te chnology review. As currently pl anned, the phase-out would apply

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to all long-chain PFOS used as a WAFS in ha rd chromium electroplating and decorative chromium electroplating. The phase-out would ha ve an effective date 3 years after promulgation of the final amendments to the Chromium El ectroplating NESHAP. Long-chain PFOS could continue to be used as a WAFS in chromium an odizing operations until such time as an effective substitute could be identified.

B. Search for Other Applicable Technology Developments

In addition to the information discusse d above, searches of the RACT/BACT/LAER Clearinghouse and the Internet we re conducted to identify other technologies or developments that could be applied to chromium electroplating. The results of these searches are described in the following paragraphs.

RACT/BACT/LAER Clearinghouse 4



### Under EPA’s New Source Review (NSR) progr am, if a company is planning to build a new plant or modify an existing plant such that air pollution emissions will increase by a large amount, the company must obtain an NSR perm it. The NSR permit is a construction permit which requires the company to minimize air pol lution emissions by changing the process to prevent air pollution and/or installing air pollution cont rol equipment.

The terms “RACT,” “BACT,” and “LAER” are acronyms for different program requirements under the NSR program. RACT, or Reasonably Available Control Technology, is required on sources in areas that are not meeti ng national ambient air quality standards (i.e., nonattainment areas). BACT, or Best Available Control Technology, is required on major new or modified sources in attainment areas. LAER, or Lowest Achiev able Emission Rate, is required on major new or modified sour ces in non-attainment areas.

BACT and LAER (and sometimes RACT) ar e determined on a case-by-case basis, usually by State or local permitting agencies . EPA established the RACT/BACT/LAER Clearinghouse, or RBLC, to provi de a central database of ai r pollution technology information (including past BACT and LAER decisions contained in NSR permits) to promote the sharing of information among permitting agencies and to ai d in future case-by-case determinations. However, data in the RBLC are not limited to sources subject to RACT, BACT, and LAER requirements. Noteworthy prevention and cont rol technology decisions and information are included even if they are not related to past RACT, BACT, or LAER decisions.

The RBLC contains over 5,000 air pollution cont rol permit determinations that can help identify appropriate technologies to mitigate mo st air pollutant emission streams. It was designed to help permit applicants and revi ewers make pollution prevention and control technology decisions for stationary air pollution sources, and includes data submitted by several U.S. territories and all 50 States on over 200 different air pollutan ts and 1,000 industrial
processes.
To identify technologies appropriate for chro mium electroplating, searches of the RBLC were made using the Process Type field for the following Process Type Codes : 99.007 - Hard

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Chromium Electroplating, 99.005 - Decorative Chromium Electroplating, and 99.002 - Chromic Acid Anodizing. All records from 1993 to 2010 were searched. No records were found for chromic acid anodizing. For hard chromium elect roplating, the search id entified information for two facilities. The elec troplating tank controls used at th ose facilities included a wet scrubber and an EED (Merlin cover). For decorative ch romium electroplating, th e search also provided information on two facilities; at one facility, the tanks were controlled with a combination chevron blade mist eliminator, wet scrubber, and mesh pad. At the othe r facility, the control method is indicated as “decreased surface area of pl ating bath.” In all cases, the control devices and methods identified through the RBLC search do not represent new tec hnologies that have not already been considered. Attach ment 2 show the results of the RBLC search for hard chromium electroplating, and Attachment 3 shows the results for the decora tive chromium electroplating search.

Internet Search

A general search of the Internet was conduc ted for information on control technologies for electroplating and anodizing tank s. The search identified a document prepared by CARB that provides a comprehensive review of the various technologies and practices used for controlling chromium emissions from electroplating and an odizing operations and for complying with the ATCM. This document (Chrome Plating and Anodizing Operations - 306 Emission Control Techniques), which is provided as Attachment 4, does not identify any cont rol technologies not already considered for th e original NESHAP or as part of this technology review. Likewise, none of the other documents and references loca ted through the Internet search identified any new practices, processes, or tec hnologies that have already been considered in this review.

III. References

1. Chromium Emissions from Chromium El ectroplating and Chromic Acid Anodizing Operations – Background Information for Pr oposed Standards, Volume I (EPA 453/R-93- 030a). Office of Air Quality Planning and Standards. U.S. Environmental Protection Agency, Research Triangle Park, NC. July 1993.

2. Long-Chain Perfluorinated Chemicals (PFC) Action Plan. Office of Pollution Prevention and Toxics, U.S. Environmental Protection Agency, Washington, D.C. December 20, 2009

3. Email from C. Richter, The Policy Group to P. Mulrine, EPA/OAQPS. PFOS Phaseout. June 3, 2010.

4. Technology Transfer Network, Clean Ai r Technology Center - RACT/BACT/LAER Clearinghouse. http://cfpub.epa.gov/rblc/inde x.cfm?action=Search.BasicSearch&lang=en.

### Attachment 1

Summary of October 2007 Amendments to Ca lifornia Airborne Toxic Control Measure for Chromium Plating and Chromic Acid Anodizing Facilities

• Bans the sale or supply of chromium elect roplating or anodizing kits to anyone other than a permitted facility

• Requires existing facilities to:

o Meet a more stringent emission limit of 0.0015 milligrams per ampere-hour (mg/A-hr)

o Comply with the revised emission limits according to a phased-in schedule that ranges from 6 months to 3 years, depe nding on the facility's permitted throughput and the distance to sensitive receptors

o Conduct a performance test to demonstrate compliance with emission limit

o Keep in place any existin g add-on control device unle ss the device is replaced with a control device that meets an emission limit of 0.0015 mg/A-hr

o Conduct a site-specific risk assessmen t if annual emissions exceed 15 grams

• For existing facilities located more than 330 f eet from a sensitive receptor, and if the annual permitted hours are no more than 50,000 A-hr per year, the facility can:

o Use a chemical fume suppressant instead of an add-on control device

o Meet a electroplating bath surface tension limit that ranges from 28 to 40 dynes per centimeter (dynes/cm), depending on th e specific fume suppressant and the instrument used to measure surface tens ion (stalagmometer or tensiometer)

• Requires new facilities to:

o Be located at least 1,000 feet from the boundary of any area zoned as residential or mixed use

o Be located at least 1,000 feet from any existing school or school under construction

o Install a HEPA filter to control emissions

o Meet a more stringent emission limit of 0.0011 mg/A-hr

o Conduct a performance test to demonstrate compliance with emission limit

• Specifies housekeeping requirements for a ll facilities to minimize emissions of fugitive dust containing chromium

• Specifies procedures for measuring elect roplating bath surface tension using a stalagmometeCOMPREHENSIVE REPORT Report Date:05/27/2010 

### Facility Information

RBLC ID: IN-0100 (final) Date Determination Last Updated: 11/13/2003 Corporate/Company Name: AK STEEL CORPORATION Permit Number: 147-6713-00041 Facility Name: ROCKPORT WORKS Permit Date: 02/13/1997 (actual) Facility Contact: FRS Number: 110017418329 Facility Description: STEEL COIL FINISHING PLANT; ALL POLLUTANTS IN PERMIT ARE LISTED SIC Code: 3316

Permit Type: A: New/Greenfield Facility NAICS Code: 331221

Permit URL: EPA Region: 5 COUNTRY: USA Facility County: Facility State: IN Facility ZIP Code: 47635 Permit Issued By: INDIANA DEPT OF ENV MGMT, OFC OF AIR (Agency Name) MS. NISHA SIZEMORE(Agency Contact) (317) 232-8356 NSIZEMOR@IDEM.IN.GOV Other Agency Contact Info: PAUL DUBENETZKY IN 317-232-8603 Permit Notes:

Process/Pollutant Information

PROCESS
NAME: BOILERS (2), NATURAL GAS FIRED, BH NO. 2

Process Type: 13.310 (Natural Gas (includes propane and liquefied petroleum gas))
Primary Fuel: NATURAL GAS
Throughput: 76.00 MMBTU/H

Process Notes: LOCATED IN BOILER HOUSE #2

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102
Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )
Emission Limit 1: 6.0800 LB/H TOTAL
Emission Limit 2:
Standard Emission: 0.0400 LB/MMBTU Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (P) LOW NOX BURNERS Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: CONTINUOUS COLD REDUCTION MILLS (5)

Process Type: 81.290 (Other Steel Manufacturing Processes)
Primary Fuel: Previous PagePrimary Fuel:

Throughput: 660.00 T/H (TOTAL)

Process Notes: VE SHALL NOT EXCEED AN AVERAGE OF 5% OPACITY IN 24 CONSECUTIVE READINGS; CERTIFIED VE READER SHALL

RECORD VISIBLE EMISSIONS ONCE PER WORKING SHIFT (DURING DAYLIGHT HOURS) FOR 12 MIN. DURING EACH OBSERVATION

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VE
Test Method: Unspecified Pollutant Group(s):
Emission Limit 1: 5.0000 % OPACITY
Emission Limit 2:
Standard Emission: 5.0000 % OPACITY Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (B) FIVE-STRAND CONTINUOUS COLD REDUCTION MILL SHALL BE ENCLOSED AND MAINTAINED UNDER NEGATIVE PRESSURE; CONTROLLED BY MIST ELIMINATOR SYSTEM Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 16.1000 LB/H
Emission Limit 2:
Standard Emission: 0.0087 GR/DSCF Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (B) FIVE-STRAND CONTINUOUS COLD REDUCTION MILL SHALL BE ENCLOSED AND MAINTAINED UNDER NEGATIVE PRESSURE; CONTROLLED BY MIST ELIMINATOR SYSTEM Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: TEMPER MILL

Process Type: 81.290 (Other Steel Manufacturing Processes)
Primary Fuel:
Throughput: 300.00 T/H

Process Notes: VE SHALL NOT EXCEED AN AVERAGE OF 5% OPACITY IN 24 CONSECUTIVE READINGS; A CERTIFIED VE READER

SHALL CONDUCT AND RECORD OBSERVATIONS ONCE PER WORKING SHIFT (DURING DAYLIGHT HOURS) FOR 12 MIN. DURING EACH OBSERVATION PERIOD

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 5.7100 LB/H
Emission Limit 2:
Standard Emission: 0.0100 GR/DSCFDid factors, other then air pollution technology considerations influence the BACT decisions: Unknown

Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (A) MIST ELIMINATOR SYSTEM Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VE
Test Method: Unspecified Pollutant Group(s):
Emission Limit 1: 5.0000 % OPACITY
Emission Limit 2:
Standard Emission: 5.0000 % OPACITY Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (A) MIST ELIMINATOR SYSTEM Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: APL STRETCH LEVELLER

Process Type: 81.600 (Pickling Processes)
Primary Fuel:
Throughput: 130.00 T/H

Process Notes: CONTINUOUS ANNEALING AND PICKLING LINE

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.0100 GR/DSCF
Emission Limit 2: 1.8900 LB/H
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (A) FABRIC FILTER Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: APL ALKALINE CLEANER

Process Type: 81.600 (Pickling Processes)
Primary Fuel:Throughput:

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.0044 GR/DSCF
Emission Limit 2: 0.3770 LB/H
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (A) WET SCRUBBER Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: ANNEALING FURNACE, SECTION NO. 1

Process Type: 13.310 (Natural Gas (includes propane and liquefied petroleum gas))
Primary Fuel: NATURAL GAS
Throughput: 72.30 MMBTU/H

Process Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102
Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )
Emission Limit 1: 1.8900 LB/H
Emission Limit 2:
Standard Emission: 0.0400 LB/MMBTU Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (P) LOW NOX BURNER Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: ANNEALING FURNACE, SECTION NO. 2

Process Type: 13.310 (Natural Gas (includes propane and liquefied petroleum gas))
Primary Fuel: NATURAL GAS
Throughput: 55.20 MMBTU/H

Process Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102
Test Method: UnspecifiedPollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )

Emission Limit 1: 2.2100 LB/H
Emission Limit 2:
Standard Emission: 0.0400 LB/MMBTU Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (P) LOW NOX BURNER Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: ANNEALING FURNACE, SECTION NO. 3

Process Type: 13.310 (Natural Gas (includes propane and liquefied petroleum gas))
Primary Fuel: NATURAL GAS
Throughput: 65.70 MMBTU/H

Process Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102
Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )
Emission Limit 1: 2.6300 LB/H
Emission Limit 2:
Standard Emission: 0.0400 LB/MMBTU Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (P) LOW NOX BURNER Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: APL AIR QUENCH SYSTEMS (6)

Process Type: 81.600 (Pickling Processes)
Primary Fuel:
Throughput: 130.00 T/H

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.0050 GR/DSCF
Emission Limit 2: 10.2100 LB/H
Standard Emission: NOT AVAILABLE Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSDOther Applicable

Requirements:
Control Method: (P) ULTRA LOW NOX BURNERS WITH INTEGRAL EXHAUST GAS RECIRCULATION (OR EQUIVALENT) Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: SHOT BLASTER CHAMBER

Process Type: 99.001 (Abrasive Blasting)
Primary Fuel:
Throughput: 130.00 T/H

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.0060 LB/H
Emission Limit 2:
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (B) FABRIC FILTER; SHOT BLAST CHAMBER TO BE ENCLOSED AND MAINTAINED UNDER NEGATIVE PRESSURE Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: ELECTROLYTIC PICKLING

Process Type: 81.600 (Pickling Processes)
Primary Fuel:
Throughput: 130.00 T/H

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.3490 LB/H
Emission Limit 2:
Standard Emission: 0.0022 GR/DSCF Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (A) WET SCRUBBER Est. % Efficiency: Compliance Verified: UnknownPollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: MIXED ACID PICKLE AND RINSE TANKS

Process Type: 81.600 (Pickling Processes)
Primary Fuel:
Throughput:

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.0030 GR/DSCF
Emission Limit 2: 0.1530 LB/H
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (B) ENCLOSE AND MAINTAIN UNDER NEGATIVE PRESSURE, WET SCRUBBER Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102
Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )
Emission Limit 1: 175.0000 PPMVD
Emission Limit 2: 6.1800 LB/H
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (B) WET SCRUBBER, ENCLOSE AND MAINTAIN UNDER NEGATIVE PRESSURE Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: SKIN PASS TEMPER MILL, APL

Process Type: 81.600 (Pickling Processes)
Primary Fuel:
Throughput: 130.00 T/H

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )Emission Limit 1: 0.0066 GR/DSCF

Emission Limit 2: 0.4590 LB/H
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (A) FABRIC FILTER Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: CPL STRIP LEVELER/MECHANICAL SCALE BREAKER

Process Type: 81.600 (Pickling Processes)
Primary Fuel:
Throughput: 476.00 T/H

Process Notes: CONTINUOUS PICKLING LINE

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.0044 GR/DSCF
Emission Limit 2: 1.5200 LB/H
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (A) FABRIC FILTER Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: HCL PICKLING BATHS/RINSE TANKS

Process Type: 81.600 (Pickling Processes)
Primary Fuel:
Throughput: 476.00 T/H

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.0020 GR/DSCF
Emission Limit 2: 0.2060 LB/H
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other ApplicableOther Applicable

Requirements:
Control Method: (B) WET SCRUBBER; ENCLOSED AND MAINTAINED UNDER NEGATIVE PRESSURE Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: ELECTROSTATIC OILER

Process Type: 81.290 (Other Steel Manufacturing Processes)
Primary Fuel:
Throughput: 476.00 T/H

Process Notes:

POLLUTANT NAME: Volatile Organic Compounds (VOC)

CAS Number: VOC
Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) )
Emission Limit 1: 3.3000 LB/GAL OIL
Emission Limit 2:
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (P) ELECTROSTATIC APPLICATION ONLY; VOC CONTENT OF RUST PREVENTATIVE OIL LIMITED TO 3.3 LB VOC/GAL OIL, EXCLUDING WATER AND EXEMPT SOLVENTS Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: CGL ALKALINE CLEANING BATHS/RINSE TANKS

Process Type: 81.290 (Other Steel Manufacturing Processes)
Primary Fuel:
Throughput:

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.1250 LB/H
Emission Limit 2:
Standard Emission: 0.0022 GR/DSCF Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (B) ENCLOSED AND MAINTAINED UNDER NEGATIVE PRESSURE; WET SCRUBBER Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:Process/Pollutant Information

PROCESS
NAME: DRYER, CGL CLEANING SECTION

Process Type: 81.290 (Other Steel Manufacturing Processes)
Primary Fuel: NATURAL GAS
Throughput: 4.10 MMBTU/H

Process Notes: CONTINUOUS GALVANIZING LINE (CGL)

POLLUTANT NAME: Sulfur Oxides (SOx)

CAS Number: 7446
Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Sulfur (SOx) )
Emission Limit 1: SEE METHOD DESCRIPTION
Emission Limit 2:
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: Other Case-by-Case Other Applicable Requirements:
Control Method: (P) INDIANA HAS RESTRICTED FACILITY TO BURNING NATURAL GAS ONLY. NO EMISSION LIMIT SET FOR SOX. Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: FURNACE, INDUCTION AND HEATING GALVANNEALING

Process Type: 12.310 (Natural Gas (includes propane and liquefied petroleum gas))
Primary Fuel: NATURAL GAS
Throughput: 205.70 MMBTU/H

Process Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102
Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )
Emission Limit 1: 12.3000 LB/H
Emission Limit 2:
Standard Emission: 0.0600 LB/MMBTU Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (A) SELECTIVE CATALYTIC REDUCTION (SCR) Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: CGL CHROMATING SECTIONProcess Type: 81.290 (Other Steel Manufacturing Processes)

Primary Fuel:
Throughput: 183.60 T/H

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.0370 LB/H
Emission Limit 2:
Standard Emission: 0.0009 GR/DSCF Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (A) WET SCRUBBER Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: HYDROGEN BATCH ANNEALING FURNACES (16)

Process Type: 13.310 (Natural Gas (includes propane and liquefied petroleum gas))
Primary Fuel: NATURAL GAS
Throughput: 6.75 MMBTU/H

Process Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102
Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )
Emission Limit 1: 9.4500 LB/H
Emission Limit 2:
Standard Emission: 0.1000 LB/MMBTU Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (P) LOW NOX BURNERS Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: DIP TANK, ELECTROLYTIC CHROME

Process Type: 99.007 (Hard Chromium Electroplating)
Primary Fuel:
Throughput:

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: GR/DSCF SEE POLLUTANT NOTES
Emission Limit 2:
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: N/A Other Applicable Requirements: NESHAP

Control Method: (A) WET SCRUBBER Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes: PM IS LIMITED TO 0.0000066 GR/DSCF ACCORDING TO NESHAP SUBPART N.

POLLUTANT NAME: Chromium Compounds, -3 only

CAS Number: 7440-47-3
Test Method: Unspecified Pollutant Group(s): ( Hazardous Air Pollutants (HAP) , InOrganic Compounds , Particulate Matter (PM) )
Emission Limit 1: 0.0150 MG/DSCM
Emission Limit 2:
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: Other Case-by-Case Other Applicable Requirements:
Control Method: (A) WET SCRUBBER Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: ELECTRODISCHARGE TEXTURING MACHINES

Process Type: 81.290 (Other Steel Manufacturing Processes)
Primary Fuel:
Throughput:

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.0120 LB/H
Emission Limit 2:
Standard Emission: 0.0020 GR/DSCF Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (A) FABRIC FILTER Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:Process/Pollutant Information

PROCESS
NAME: BOILERS (3), NATURAL GAS FIRED, BH NO. 1

Process Type: 13.310 (Natural Gas (includes propane and liquefied petroleum gas))
Primary Fuel: NATURAL GAS
Throughput: 76.00 MMBTU/H

Process Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102
Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )
Emission Limit 1: 9.1200 LB/H TOTAL
Emission Limit 2:
Standard Emission: 0.0400 LB/MMBTU Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (P) LOW NOX BURNERS Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: COOLING TOWERS (2), NON-CONTACT

Process Type: 99.009 (Industrial Process Cooling Towers)
Primary Fuel:
Throughput:

Process Notes:

POLLUTANT NAME: Particulate Matter (PM)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.0050 % DRIFT
Emission Limit 2:
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (A) DRIFT ELIMINATORS Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:



### Facility Information Previous PageRBLC ID: CA-0650 (final) Date Determination Last Updated: 12/18/2001 Corporate/Company Name: KING INDUSTRIAL HARD CHROME Permit Number: A/C NO. C-2494-1-0 Facility Name: KING INDUSTRIAL HARD CHROME Permit Date: 06/30/1995 (actual) Facility Contact: FRS Number: 110017401863 Facility Description: SIC Code: 3471 Permit Type: A: New/Greenfield Facility NAICS Code:

Permit URL: EPA Region: 9 COUNTRY: USA Facility County: FRESNO Facility State: CA Facility ZIP Code: Permit Issued By: SAN JOAQUIN VALLEY APCD - CENTRAL REGIONAL OFFICE, CA (Agency Name) MR. GEORGE HEINEN(Agency Contact) (559) 230-6000 Other Agency Contact Info: SEYED SADREDIN CA (209) 468-3474 Permit Notes:

Process/Pollutant Information

PROCESS
NAME: HARD CHROME PLATING OPERATION

Process Type: 99.007 (Hard Chromium Electroplating)
Primary Fuel:
Throughput: 5.00 MM AMP-HR/YR

Process Notes: COMPLIANCE TO BE VERIFIED BY SOURCE TEST

POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)

CAS Number: PM
Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.0700 MG/AMP-HR
Emission Limit 2:
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: Other Case-by-Case Other Applicable Requirements:
Control Method: (B) MERLIN SEALED AND ENCLOSED TANKS COVERED WITH 0.1 MICRON TEFLON VENT FILTER Est. % Efficiency: 99.000 Compliance Verified: Unknown Pollutant/Compliance Notes:

Previous PageCOMPREHENSIVE REPORT Report Date:05/27/2010 

### Facility Information

RBLC ID: OH-0219 (final) Date Determination Last Updated: 10/09/2002 Corporate/Company Name: SUPREME BUMPER, INC. Permit Number: 04-832 Facility Name: SUPREME BUMPER, INC. Permit Date: 07/09/1993 (actual) Facility Contact: FRS Number: 110000383969 Facility Description: SIC Code: 3471 Permit Type: A: New/Greenfield Facility NAICS Code: 332813

Permit URL: EPA Region: 5 COUNTRY: USA Facility County: Facility State: OH Facility ZIP Code: Permit Issued By: CITY OF TOLEDO, ENV SERVICES DIV, OH (Agency Name) MS. KAREN GRANATA(Agency Contact) (419)936-3952 karen.granata@ci.toledo.oh.us Other Agency Contact Info: BOB KOSSOW OH (419) 697-5104 Permit Notes: 1. Emission Limits Set as Tlv at the Stack Discharge with Modeling of Ground Level Concentrations < Tlv-42.

Process/Pollutant Information

PROCESS
NAME: EVAPORATOR

Process Type: 99.005 (Decorative Chromium Electroplating)
Primary Fuel:
Throughput: 160.00 LB H20/H

Process Notes:

POLLUTANT NAME: Chromium / Chromium Compounds, -3 & -6

CAS Number: 7440-47-3
Test Method: Unspecified Pollutant Group(s): ( Hazardous Air Pollutants (HAP) , Heavy Metals , InOrganic Compounds , Particulate Matter (PM) )
Emission Limit 1: 0.0005 LB/H
Emission Limit 2: 0.0500 MG/M(3)
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: Other Case-by-Case Other Applicable Requirements:
Control Method: (A) CHEVRON ELIMINATORS, WET SCRUBBER, & MIST PAD Est. % Efficiency: 99.000 Compliance Verified: Unknown Pollutant/Compliance Notes:



### Facility Information Previous Page

Previous PageRBLC ID: VA-0193 (final) Date Determination Last Updated: 10/03/2002 Corporate/Company Name: HOECHST CELANESE CORPORATION Permit Number: 20304 Facility Name: HOECHST CELANESE CORPORATION Permit Date: 02/25/1993 (actual) Facility Contact: DOUGLAS FEUERBACH FRS Number: 110000343147 Facility Description: SIC Code: 2823 Permit Type: A: New/Greenfield Facility NAICS Code: 325221

Permit URL: EPA Region: 3 COUNTRY: USA Facility County: GILES Facility State: VA Facility ZIP Code: 24124- Permit Issued By: VIRGINIA ENVIRONMENTAL QUALITY AIR DIV. (Agency Name) MS. MONICA A. HARVEY(Agency Contact) (804)698-4300 MAHARVEY@DEQ.VIRGINIA.GOV Other Agency Contact Info: STEVE DIETRICH VA (540) 562-6762 Permit Notes: 1. TESTING WAS REQUIRED. 2. THROUGHPUT CAPACITY OF CIGARETTE TOW PRODUCTION FACILITY WAS DECLARED CONFIDENTIAL. 3. IN ADDITION TO THE CARBON ADSORPTION UNITS, THE PLANT HAS INSTALLED SEVERAL ADDITIONAL INNOVATIVE CONTROLS TO REDUCE THE AMOUNT OF ACETONE EMISSIONS. THE RESULT IS AN EXPANSION IN CAPACITY WITHOUT AN INCREASE IN EMISSIONS. 4. CAPACITY AND EMISSION LIMIT FOR CHROME PLATING OPERATION LISTED AS "NA". 5. DETERMINATION FOR A CIGARETTE TOW PRODUCTION FACILITY. 6. PORTIONS OF FACILITY STARTED UP IN MARCH 1989.

Process/Pollutant Information

PROCESS
NAME: CIGARETTE TOW PRODUCTION FACILITY

Process Type: 65.999 (Other Synthetic Fibers Production Sources)
Primary Fuel:
Throughput: 0

Process Notes:

POLLUTANT NAME: Acetone

CAS Number: 67-64-1
Test Method: Unspecified Pollutant Group(s):
Emission Limit 1: 5204.0000 T/YR
Emission Limit 2: 433.7000 T/MO
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (A) CARBON ADSORPTION Est. % Efficiency: 98.900 Compliance Verified: Unknown Pollutant/Compliance Notes:

Process/Pollutant Information

PROCESS
NAME: PLATING, CHROME

Process Type: 99.005 (Decorative Chromium Electroplating)
Primary Fuel:
Throughput:

Process Notes: PROCESS (CHROME PLATING) IS USED IN CONFUNCTION WITH THE PRODUCTION OF SYNTHETIC FIBER FORProcess Notes: PROCESS (CHROME PLATING) IS USED IN CONFUNCTION WITH THE PRODUCTION OF SYNTHETIC FIBER FOR
CIGARETTE TOW.

POLLUTANT NAME: Chromium Compounds, -6 only

CAS Number: 7440-47-3
Test Method: Unspecified Pollutant Group(s): ( Hazardous Air Pollutants (HAP) , InOrganic Compounds , Particulate Matter (PM) )
Emission Limit 1: NOT AVAILABLE
Emission Limit 2:
Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown
Case-by-Case Basis: BACT-PSD Other Applicable Requirements:
Control Method: (P) DECREASED SURFACE AREA OF PLATING BATH Est. % Efficiency: 70.000 Compliance Verified: Unknown Pollutant/Compliance Notes:

Previous Page

### Chrome Plating and Anodizing Operations

Cal/EPA – January 2006 1



# 306 EMISSIONS CONTROL TECHNIQUES

TABLE OF CONTENTS

306 EMISSIONS CONTROL TECHNIQUES 306.1 FUME SUPPRESSANTS 306.1.1 Chemical Fume Suppressants 306.1.2 Mechanical Fume Suppressants

306.2 ADD-ON CONTROL DEVICES 306.2.1 Capture Techniques 306.2.2 Pack-Bed Scrubbers 306.2.3 Mist Eliminators 306.2.4 HEPA Filters 306.2.5 Combination Systems 306.2.6 Encapsulating Tank Covers



# 306 EMISSIONS CONTROL TECHNIQUES

To comply with the State ATCM regulation, a plating or anodizing facility must either

1. Meet a surface tension limit using chemical fume suppressants containing a wetting agent or; 2. Meet an emission limit (mg/amp-hr or mg/dscm) demonstrated by a performance test.

Techniques to control hexavalent chromium emissions from chrome electroplating and anodizing tanks include fume suppressants and add-on control devices. In the first, an anti-mist additive is added to the plating bath to reduce the amount of misting that takes place. In the second, the mist is captured, and the entrained chromium is extracted from the exhaust air stream prior to discharge to the stack.

In California, decorative platers typically use an anti-mist additive to achieve compliance with theState's hexavalent chromium emissions limit. About 25% of decorative platers in the State uses addon control equipment in addition to an anti-mist additive. About 5% use only add- on control equipment 

### to reduce hexavalent chromium emissions.

Hard chrome platers in California use add-on controls to achieve compliance with the State's hexavalent chromium emissions limit. However, about 50% of hard chrome platers in the State use an 

### anti-mist additive in conjunction with add-on controls to reduce hexavalent chromium emissions from their tanks.

### Chrome Plating and Anodizing Operations

Cal/EPA – January 2006 2 About 40% of chromic acid anodizing operations in th e State use an anti-mist additive alone to achieve compliance. Another 40% use an anti-mist additive in conjunction with add-on controls. The remaining 20% use only add-on controls to reduce hexavalent chromium emissions from their tanks. 6



## 306.1 FUME SUPPRESSANTS

Fume suppressants are mist suppressant or physical barriers at the surface of the plating bath used to control chromic acid mists. There are two categories of fume suppressants: chemical fume suppressant and mechanical fume suppressant.


## 306.1.1 Chemical Fume Suppressant

A chemical fume suppressant is any chemical agent that reduces or suppresses fumes or mists at the surface of an electroplating or anodizing bath. Another term for chemical fume suppressant is mist suppressant. Fume suppressants can be temporary or permanent depending on the mechanism of depletion from the baths. Temporary fume suppressants are depleted mainly by the decomposition of the active chemical components. Permanent fume suppressants are depleted by drag-out of the solution.

Chemical fume suppressants are added directly to the bath to reduce or inhibit misting. Chemical fume suppressants include: wetting agents, foam blankets (Figure 306-1), and combinations of both (Figure 306-2). Most chemical fume suppressants in use today contain wetting agents. The difference between wetting agents and foam blankets is the way in which they reduce emissions. Wetting agents 

### control misting by lowering the surface tension of the bath, while foam blankets physically suppress the mists produced on the surface of the bath.

Fume suppressants are manufactured in liquid, powder, or tablet form. Some of the main advantages of using chemical fume suppressants include:

1. Minimization of plating solution evaporation losses; 2. Low cost of chromium emission control; 3. Very little energy consumption; and 4. No solid waste generation.

Limitations in using chemical fume suppressants include:

1. Some fume suppressants have a tendency to aggravate gas pitting and defects in base metals; and 2. Foam blankets that are too thick can entrap hydrogen gas, which poses a risk of explosion.

Chemical fume suppressants typically reduce chromium emissions between 93 and 99 percent. 1



### 306.1.1A Foam Blankets

A foam blanket is a type of chemical fume suppressant that generates a layer of foam across the surface of a solution when current is applied to that solution. Foam blankets do not prevent the formation of chromic acid mist, but instead trap the mist under a blanket of foam. The foam blanket is

### Chrome Plating and Anodizing Operations

Cal/EPA – January 2006 3 formed by the agitation produced by hydrogen and oxy gen gas bubbles generated during electroplating. Once formed, the foam blanket is usually maintained at a thickness of 1.3 to 2.5 centimeters (0.5 to 1.0 inches) and covers the entire surface of the plating bath (see Figure 306-1). The ability of the foam layer to contain mist is greatly reduced if proper thickness is not maintained. If the foam blanket is too thin, less than 1.3 centimeters (0.5 inches), it will no longer trap the chromium containing mist. Conversely, a thickness greater than 2.5 centimeters (1.0 inches) will cause hydrogen gas to build up in the foam layer, creating a hydrogen explosion hazard should a spark be generated from the contacting equipment. These problems tend to occur more frequently with higher current densities and longer plating times. 1



### Figure 306-1. Foam Blanket

The characteristics of foam blanket solutions are determined by the surface area of the solution, amount of current applied, and temperature and chromic acid concentration of the plating bath, (e.g. less suppressant is required at lower temperatures). Visual monitoring of the thickness of the foam blanket is the most common method for determining when to add foam blanket solution to the bath. The frequency of adding foam blanket solution, also, depends upon the drag-out rate of the solution and the amount of work being performed in the plating tank. Chemical decomposition, to a greater extent than drag-out, is the primary mechanism for depletion of foam blankets.

306.1.1B Wetting Agents

A wetting agent is a type of chemical fume suppressant that reduces the surface tension of a liquid. When wetting agents lower the surface tension of a plating bath, gases escape at the surface of the solution with less of a "bursting" effect, causing less mist formation. In essence, a wetting agent reduces bubble size, and smaller bubbles burst with less impact on the surface.

Plating bath typically have a surface tension of 70 dynes/cm. With the addition of sufficient wetting agent, the surface tension of the plating bath can be reduced to 45 dynes/cm or less where it has been shown to create a rapid reduction in chromic acid emissions. 1 

### The two methods used to measure the surface tension of the plating solution are the stalagmometer (the drop weight method)

### Chrome Plating and Anodizing Operations

Cal/EPA – January 2006 4 and the tensiometer (the ring method). Most plating facilities use a stalagmometer to measure the surface tension. Go to the Photo Gallery to view pictures of the stalagmometer and the tensiometer.

Figure 306-2. Fume Suppressant - Combination of Wetting Agent and Foam



## 306.1.2 Mechanical Fume Suppressant

A mechanical fume suppressant is any device that reduces fumes or mist at the surfaces of an electroplating or anodizing bath by direct contact with the surface of the bath. Polyballs (Figure 306-3) are the most commonly used mechanical fume suppressant. Polyballs are hollow, plastic floating spheres with typical sizes range from 3/4 to 2 inches in diameter. They are fabricated from plastics that are resistant to chemical attack and are used to reduce heat loss, bath evaporation, and misting. In order to be most effective, balls must cover the entire surface area of the bath.

### Chrome Plating and Anodizing Operations

Cal/EPA – January 2006 5 Figure 306-3. Polyballs

The U.S. EPA has examined the use of these floating spheres for air pollution control purposes, and found them to be of limited use. In one such test, a two to three inch layer of 1.5 inches in diameter spheres achieves a removal efficiency of only about 75 percent. 1 

### The effectiveness of polyballs is also 

### reduced by the fact that the evolution of hydrogen gas at the workpiece tends to push the spheres away, exposing a portion of the plating bath surface to the air above.



## 306.2 CONTROL DEVICES

This section discusses the capture techniques to capture the chromium misting at the surface of the tank and the add-on control devices available to extract the entrained chromium from the exhaust air stream prior to discharge to the stack. An add-on air pollution control device is any equipment installed in the ventilation system of chrome electroplating and anodizing tanks for the purposes ofcollecting and holding chromium emissions from the tank(s). Add-on control devices include: packbed scrubbers, mesh pad mist eliminators, fiber bed mist eliminators, and combination systems. Also discussed is the encapsulating tank cover which does not require an exhaust stack to vent process air 

### outside of the facility.


## 306.2.1 Capture Techniques - Lateral Exhaust System

Local exhaust ventilation is the most common method used to capture chromic acid mist from chrome plating and chromic acid anodizing baths. Typical local exhaust ventilation equipment includes lateral (slot) and push-pull exhaust hoods. Canopy hoods or overhead exhaust hoods and enclosures are normally not used because they restrict access to the plating or anodizing tank. In addition, overhead

### Chrome Plating and Anodizing Operations

Cal/EPA – January 2006 6 hoods would draw mists from the tank surface into th e breathing zone of anyone who was working at the tank. However, there is a control system called the encapsulating tank lid or cover used by hard chrome platers that contains the mist while allowing other gasses to vent. This control system is further discussed in Subsection 306.2.6, Encapsulating Tank Covers.

A tank is said to be "laterally exhausted" if the hood does not project over the entire tank and the direction of the air movement into the hood is substantially horizontal. Lateral exhaust systems typically used to control chromic acid mist from open-surface tanks include both single-sided and double-sided slot hoods. The slot velocity affects the uniformity of airflow distribution along the length of the hood.

Single-sided hoods have a maximum reach across the width of the tank of about 30 inches (2 and 1/2 feet) while double-sided hoods have a maximum reach of about 60 inches (5 feet). In this system, the chromic acid mists are collected by slot vents which usually run along the long side (single-sided) or along both long sides of the tank (double-sided) (see Figure 306-4).

Figure 306-4. Slot Vents on a Lateral Exhaust System

Push-pull ventilation is recommended for tanks greater than 42 inches (3 and 1/2 feet) in width. In a

### Chrome Plating and Anodizing Operations

Cal/EPA – January 2006 7 push-pull system (Figure 306-5), one slot vent is an intake ("pull") while the other supplies air under pressure ("push"). Push air supplied through slots, orifices, or nozzles is blown across the width of the tank to direct contaminated air toward the exhaust hood, the "pull" vent, located on the opposite side of the tank.

Figure 306-5. Push-Pull System



## 306.2.2 Packed Bed Scrubbers

A packed-bed scrubber (PBS) consists of a single or double packed bed that contains packing media on which the chromic acid droplets attach. First, the gas stream is wetted by spraying water against the flow of the gas to make the droplets larger. Then the gas stream passes through the packed bed(s) where the droplets attach onto the packing media. A mist eliminator section follows the packed bed section of the scrubber. The mist eliminator removes any water entrained from the packed bed section. Treated gases then pass through an induced draft fan and out a stack of exhaust vent. The scrubber water is recirculated and periodically tapped and discharged to the electroplating tanks as makeup solution. Figure 306-6 shows a packed-bed scrubber.

### Chrome Plating and Anodizing Operations

Cal/EPA – January 2006 8 A PBS has a typical efficiency of 97 percent for dec orative chromium electroplating and anodizingtanks and 99% for hard chromium electroplating tanks. Factors influencing efficiency include: liquidto-gas ratio (the flooding or starving of the media with scrubbing liquor), gas velocity, surface area and type of packing media, distribution of the media in the bed, and effectiveness of washdown procedures. 3



### Figure 306-6. Packed-Bed Scrubber

(Courtesy of Midwest Air Products Co., Inc. (MAPCO), adapted)



## 306.2.3 Mist eliminators

Mist eliminators generally remove droplets from gas streams by inertial impaction of droplets on these devices and centrifugal force applied to the gas stream. Many types of mist eliminating devices have been developed, but most are categorized within the following types: chevrons, mesh pads, and fiber beds.

Mist eliminators may be used in a horizontal or vertical gas flow configuration. When mist eliminators are used on a vertical gas stream, liquids removed from the gas will drip from the eliminator from the force of gravity on the liquid against the flow of the gas stream. Liquids collected by mist eliminators used on horizontal gas flows will not drip against the flow of the gas, so horizontal mist eliminators can handle higher gas velocities and liquid loadings.

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Cal/EPA – January 2006 9 Mist eliminators are usually equipped with liquid sp rays to prevent the accumulation of solids. An accumulation of solids can plug part of the eliminator, reduce the area of flow, create excessive pressure drops and increase liquid entrainment. Properly operating mist eliminators usually have a pressure drop between 0.5 and 4.0 inches of water. Type, size, and composition of the pads are dependent on the system they are incorporated in (i.e. gas density, flow velocity, etc.).

306.2.3A Chevron-Blade Mist Eliminators

Chevrons are devices composed of zigzag baffles which force a gas stream to turn sharply. Liquids collect on the blades of the chevron and drain downward by gravity. Basically, a series of parallel zigzag blades (see Figure 306- 7) are positioned in the body or housing of the device, in order to direct 

### the air flow through narrow passageways that repeatedly change its direction by approximately 30 degrees. At regular intervals, the extruded blades have narrow vertical channels which serve to capture some of the chromium droplets by inertial forces. Since the channels are oriented in a vertical plane, condensed chrome is transported to a drain at the bottom of the housing. Common blade designs are the overlapping and sinusoidal wave designs (see Figure 306-7).

Figure 306-7 Blade Configurations Used in Chevron Mist Eliminators (EPA Capsule Report)

Blade-type horizontal mist eliminators have demonstrated a wide efficiency range. Removal efficiencies ranged from about 83 to 99 percent. Some of the factors influencing efficiency were: gas velocity, blade spacing, seal integrity, and wash down frequency. 1, 3



### 306.2.3B Composite Mesh Pad Mist Eliminators

A composite mesh pad mist eliminator (CMP) consists of several layers of interlocked fibers densely packed between two supporting grids. The composite mesh pad was developed to remove small particles (< 5 micrometers or 0.2 mils) that were not effectively controlled by other control devices. There are usually at least three mesh pad stages (see Figure 306-8). The first stage removes large particles. The second stage removes smaller particles using a composite mesh pad. The final stage may remove any reentrained particles not collected by the composite mesh pad in the second stage.

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Cal/EPA – January 2006 10 A reentrained particle is a particle which was caugh t by the mesh pad, but some force removed it from the mesh pad and returned it to the air stream.

The layers of material in composite pads are arranged with the smallest diameter fiber layer located in 

### the center of the pad and progressively larger diameter layers located on both sides of the center. Particles collide with the fibers in the pad and attach to the fiber surfaces. These captured particles combine into larger particles as they travel through the small diameter fiber layers in the center of the pad. These larger particles either drain to the bottom of the unit or are reentrained in the gas stream. The reentrained particles are then captured by the large diameter fiber layers in the back of the pad.

CMP systems incorporate a larger particle removal system located upstream from the composite mesh pad, to reduce the plugging potential of the pad. The large particle removal system can either be a series of larger diameter mesh pads or a packed bed scrubber section. Typical removal efficiencies associated with this control device are greater than 99 percent. 1, 3



### Figure 306-8. Mesh Pad Mist Eliminator (Courtesy of Midwest Air Products Co., Inc. (MAPCO), adapted)

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Cal/EPA – January 2006 11 306.2.3C Fiber Bed Mist Eliminators

A fiber bed mist eliminator (FBME) removes contaminants from a gas stream through the mechanisms of inertial impaction and Brownian diffusion. FBMEs have most often been used to reduce acid mists from sulfuric, phosphoric, and nitric acid plants. An FBME consists of one or more fiber beds. Each bed consists of a hollow cylinder formed from two concentric screens (see Figure 306-9). The fiber between the screens may be made of glass, ceramic, plastic, or metal. Fiber bed units are designed for horizontal, concurrent gas liquid flow through the fiber bed. The contaminated gas stream flows toward the downstream face of the bed. The acid mist in the gas stream impacts on the surface of the fibers and drains down the outer face of the bed to the sump while the clean gas flows up and out the top of the unit.

Figure 306-9 Fiber Bed Mist Eliminator (EPA Capsule Report)

A FBME device is typically installed downstream from another control device that can prevent plugging of the FBME device. The upstream device removes the majority of the emissions and thus prevents plugging of the fiber bed.

To date, there is no adequate test data available to accurately quantify the control efficiency of FBME. The U.S. EPA believes that these systems can achieve the same emission limits as CMP systems and chemical fume suppressants. 1, 3

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Cal/EPA – January 2006 12 

## 306.2.4 HEPA Filters

A High Efficiency Particle Arresting or Particulate Air (HEPA) filter is defined by the Department of Energy (DOE) as a throwaway, extended-media, dry type filter with a rigid casing enclosing the full length depth of the pleats. The filter shall exhibit a minimum efficiency of 99.97% when tested at an aerosol of 0.3 micrometers diameter. 5 

### These filters were originally designed to trap microscopic particles such as radioactive dust in atomic plants and are commonly used for critical environments like hospitals, clean rooms, and lead abatement projects. Figure 306-9 illustrates a HEPA filter system.

Figure 306-9. HEPA Filter System

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Cal/EPA – January 2006 13 

## 306.2.5 Combination Systems

Combination systems are various arrangements of multiple control devices, as discussed above, in a common exhaust system. Some of the variations include:

1. Mesh pads installed in exhaust hoods at the tank, followed by an end-of-line mesh pad or packed bed scrubber;
2. In-line mesh pad mist eliminators, located after the exhaust hoods, followed by an end-ofline mesh pad or packed bed scrubber;
3. Blade-type horizontal mist eliminators followed by an end-of-line mesh pad or packed bed scrubber; 4. Mesh pad mist eliminator system followed by a high efficiency particulate air (HEPA) filter as a final polishing device; and
5. Mesh pad mist eliminator system followed by a filter bed as a final polishing device.

Some of the advantages in using multiple devices include: segregating chemicals, keeping duct work clean, and reducing the inlet loading on the end-of-line unit. 1



## 306.2.6 Encapsulating Tank Covers

An encapsulating tank cover involves the use of a special tank hood or cover that contains the mist while allowing other gasses to vent (see Figure 306-10). The system does not require an exhaust stack to vent process air outside of the facility. The hydrogen and oxygen gas, generated during the chrome plating process, pass through a selective membrane system to the plating room environment. Water vapor and chromic acid mist do not penetrate the membrane, but will condense within the confines of the tank's cover. At the end of the plating batch, an evacuation cycle removes latent fumes or mists prior to opening the cover for partial retrieval. This approach can reduce the building's energy requirements significantly, since the unit does not exhaust conditioned air outdoors, and there are no large fan motors. An additional benefit is that no chromium-bearing fluids are generated, aswith the washdown cycles of mesh pad mist eliminator systems or the recirculated liquor in packedbed scrubbers.

### Chrome Plating and Anodizing Operations

Cal/EPA – January 2006 14 Figure 306-10. Encapsulating Tank Cover (EPA Capsule Report, PF Online)

Because water vapor is not removed from the plating bath through surface evaporation, reclaim rinsing strategies and cooling systems may be adversely affected. Also, parts should either have identical start/stop times (i.e., batch plated) or be capable of multiple plating cycles, since all plating in the tank must be stopped before any parts can be added or removed. 1, 4

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Cal/EPA – January 2006 15 

# References

1.U.S. EPA, 1998, Capsule Report-Hard Chrome Fume Suppressants and Control Technologies

, Office of Research and Development, Washington DC, Document No. EPA/625/R-98/002, December 1998, Available online at: http://www.epa.gov/ORD/NRMRL/pubs/625r98002/625r98002.pdf

2. U.S. EPA, 1993, Chromium Emissions from Chromium Electroplating and Chromic Acid Anodizing Operations-Background Information for Proposed Standards , Document No. EPA 453/R-93-030b, p. 4-1 - 4-70

3. Colorado Department of Public Health and Environment (CDPHE), 1999, CDPHE Chromium MACT - Control Measures , Last updated April 21, 1999, Accessed January 20, 2005, http://www.cdphe.state.co.us/ap/chromium/html/control/index.html

4. PF Online an online component of Products Finishing magazine, 1997, Reducing Hexavalent Chromium Emissions, December 1997, Accessed on May 25, 2004, http://www.pfonline.com/articles/129705.html

5. U.S. Department of Energy, 1997, DOE Standard Specification for HEPA Filters Used By DOE Contractors , Document No.: DOE-STD-3020-97, Washington, D.C., January 1997, p. 4, Accessed on September 21, 2005, http://www.eh.doe.gov/hepa/docs/std3020.pdf

6. California Air Resources Board, telephone discussion with Shobna Sahni, Lead staff on ATCM for Chrome Plating and Chromic Acid Anodizing Operations, September 2005

7. California Air Resources Board, 2000, Toxics Enforcement Manual, Part B: NESHAP/MACT Guideline Documents, Volume 2, Chapter I, Chrome Electroplating and Anodizing Operations

, Compliance Assistance Program, Sacramento, CA, November 2000, p. 200-12 - 200-18