From: "Jeff Hannapel" < jhannapel@thepolicygroup.com >

To: Phil Mulrine/RTP/USEPA/US@EPA

Cc: "'Christian Richter'" < crichter@thepolicygroup.com >

Date: 05/21/2012 03:49 PM

Subject: Data for Revised Chromium Emissions Estimates

Phil,

Attached is a summary of some of the data used for the revised emissions

estimates that we provided you in the NASF comments and supplemental

information. As we discusse d, in addition to this data, we received

information directly from facilities regarding their emissions.

Furthermore, some of the emissions estimates were based on information

provided by the facility of chemical suppliers that indicated that the

facility has very small chromium plating line, e.g., only a single small

tank that had limited plating capacity.

The facility closures are straightforward and should be easy to verify with

a phone call, some research or site visit, which is how we determined

facil ity closures. The facilities that no longer have hard chromium

processes or any chromium plating processes were listed as they were

reported to us. The trends from this analysis are clear, with a significant

number of facility closures and a significant number of facilities that no

longer have chromium electroplating processes. If you have any questions

regarding the attached information or regarding any of the results from our

survey of facility emissions, please contact Christian or me.

We look forward to talking with you later this week.

Best regards,

Jeff



### (See attached file: NASF Chrome MACT Facility Emissions Data.docx)

# Data to Support NASF Chromium Emissions Estimates

Provided to EPA in Comments

Surface Finishing Technology, Elmira, NY

In 1991 we had our exhau st tested; the va lues were determined to be at levels of 0.030mg /dscm

or less which equated to 0.8lbs/yr; 1/10th of the permit value. The NYS record was up dated in

the spring of 1997 with a formal submission of the 0.8lbs / yr value at the same time as all of our

emissions including everything even combustion products from our boilers. The form from NYS

was completed in April 1997. This value remained consistent through June of 1997 at which time

we installed CMP system.

The NYS information was updated in July of 1997 with the test results of the CMP system. The

values achieved with the CMP were 0.005mg/ ds cm well below the newly established limit, the

test didn't even include the use of fume suppressant which we did continue to use for worker

safety and a cleaner exhaust system.

The annual value based on 24/7/365 calculated out to be 0.377lbs/yr max based on 24/7/365

which we do not run. Our operation is more on the 24/5.5/250 which is 78%of full year 24/7/365

this would make the 0.295lbs/yr.

NEO Industries (four separate facilities)

Plant Air Flow (CFM) Avg. Air

Flow

(m3/hr) Emissions

(mg/m3) Emissions

(Lbs/Hr.) Total

Annual

Amp

Hours Annual

Emissions

(Lbs/Yr)

Indiana 32000 54368 0.009 0.00108 2265 2.438253177

West Virginia 10000 16990 0.00011 0.00000 1545 0.006352421

Alabama 15500 26335 0.007 0.00041 2400 0.973327703

Kentucky 27000 45873 0.00062 0.00006 1400 0.087599493

### Schumacher , Houston, TX

CHROME EMISSION SYSTEMS “A” “B” “C”

EF1 = Emission Factor Cr Compounds Hard Chrome

(grains/amp

- hr)

0.12 0.12 0.12

A 1 = Maximum Installed Rectifier Capacity (amps)

24,500 39,000 42,000

A 2 = Maximum Cumulative potential rectifier capacity

24,500 39,000 42,000

ER1 = Total Emission Rate Cr Compounds (lbs. hr.)

0.42 0.668571429 0.72

CE = Hood Capture Efficiency (%)

99.99 99.99 99.99

AE = Abatement Device Efficiency [1

- ( %)/100]

99.99 99.99 99.99

AE = [1

– (%)/100 where % is the Abatement device efficiency]

0.0001 0.0001 0.0001

ER3 = (lbs./Hr.) Total Emission Rate Cr Compounds (No Fume

Suppressant)

0.42 0.668571429 0.72

ER5 = (lbs./Hr.) Cr Compounds Entering Abatement Device

0.419958 0.668504571 0.719928

ER3

– ER5 (lbs./hr.) Cr Compounds Entering Atomsphere

4.2E

- 05 6.68571E

- 05 7.2E

- 05

ER7 = Emission Rate Cr Compound Controlled (lbs./hr.)

ER7 = ER5 x AE (lbs./hr.)

4.19958E

- 05 6.68505E

- 05 7.199E

- 05

FUG1 = Cr Compounds Fugitive Emission Rate (lbs./hr.)

FUG1 = (ER3

– ER5)(0.5)(lbs./hr.)

2.1E

- 05 3.34286E

- 05 3.6E

- 05

OY = Total Operating Hours per year

8760 8760 8760

AFUG1 = Annual Total Cr Comp. Fugitive Emission Rate

(tons/year)

AFUG1 = (FUG1 x OY)/2000 (tons/year)

9.198E

- 05 0.000146417 0.0001577

AER1 = Annual Cr Comp. Emission Rate (tons/year)

AER1 = (ER7 x OY)/2000 (tons/year)

0.000183942 0.000292805 0.0003153

(lbs./hr.) COMBINED EMISSIONS CONTROLLED &

FUGITIVE:

6.29958E

- 05 0.000100279 0.000108

TOTAL (LBS/HR) SYSTEMS "A", "B" & "C"

- CONTROLED +

FUGITIVE EMISSIONS : 0.000271

TOTAL COMBINED ANNUAL EMISSIONS CONTROLLED +

FUGITIVE (tons/year)=

0.0002759 0.0004392 0.000473

TOTAL COMBINED ANNUAL EMISSIONS CONTROLLED +

FUGITIVE: A, B, C (tons/year) 0.001188

### Gull Industries, Houston, TX

This facility has a scrubber with composite mesh pad system and uses fume suppressants for its

decorative chrome plating operation. Using AP42 emissions factors with a removal efficiencies

of 99.9% for the scrubber and 90% for the fume suppressant, the an nual chrome emissions are

0.003 pounds.

Hytek Finishes, Kent, WA (December 12, 2011 letter)

### Lincoln Plating, Lincoln, NE

Revised annual emission s of 1.03 pounds (as opposed to EPA estimate of 4.1 pound annual

emissions ) are based on data from the facility’s most recent annual inventory of emissions

.

Action Rotary Die, Addison, IL

Alloy Chrome, Schiller Park, IL

CMP Anodizing Corp., Elk Grove, IL

Cro

- Mat Co., Lincolnwood, IL

HBM Co., Lansing, IL

For these five facilities, the annual emission s were calculated using AP

- 42's emission factor for

hard chrome plating (listed in IEPA's AER instruction booklet as 0.0000171 lbs per amp

- hr). A

98 percent control efficiency was applied to account for the pollution control device . This

conservative control e fficiency was used to calcu late emission estimates to make sure that the

control efficiency of each facility’s actual device isn't overstated. (Note: many AP

- 42 emission

factors are provided in units other than lbs/amp

- hr

-- the IEPA provided emission factors account

for unit conversions and not identical to EPA's AP

- 42 document).

Depending on the specific data that are available, the annual emissions were calculated using

actual calendar year amp hours or production data

, ( annua l amp

- hrs are calculated from

production data such as average amperage and total hours plating; amperage and plating time per

part and total number processed).

While these emissions based on emissions factors and conservative control efficiencies may

over state the actual annual emissions for these facilities, we are trying to locate recent stack test

data from one of more of these facilities to compare the emissions based on stack test and

emissions factors.