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

To: Janet McCabe/DC/USEPA/US@EPA, Steve Page/RTP/USEPA/US@EPA, Peter

Tsirigotis/RTP/USEPA/US@EPA, Steve Fruh/RTP/USEPA/US@EPA, Mike

Koerber/RTP/USEPA/US@EPA, Chuck French/RTP/USEPA/US@EPA, Emily

Atkinson/DC/USEPA/US@EPA

Cc: "'Christian Richter'" < crichter@thepolicygroup.com >, "Stu Sessions" < sessions@environomics.com >

Date: 03/20/2012 05:12 PM

Subject: Materials for Meeting on Chromium Electroplating MACT Revisions

Greetings,

On behalf of the National Association for Surface Finishing, we look forward

to meeting with you tomorrow at 3:00 PM regarding the supplemental proposal

on the chromium electroplating MACT revisions. Please find attached two

documents that will provide some background for our discussions.

If you have any questions or would like to discuss anything prior to the

meeting, please contact Christian Richter or me.

Best regards,

Jeff

Jeffery S. Hannapel

The Policy Group

202

- 257

- 3756

(See attached file: NASF Chrome MACT Summary of Emissions Corrections.xlsx )(See attached file: NASF Chrome

MACT Gull Industries PFOS Replace Results 2012.doc)

# Summary of Hexavalent Chromium Emissions

Company Location Process EPA Emissions

Estimate

(lbs/yr) Corrected

Emissions

(lbs/yr) Percentage

Difference Reason for Correction

Action Rotary Die

Inc. Addison, IL Hard 1.9 0.125 93% Revised data provided by facility

Advanced Graphics

Tech Grapevine, TX Hard 1.9 0.6 68% Revised data provided by facility

AH Metal

Fabricators Moore, OK Hard 1.8 0 100% Facility is closed

Alloy Chrome Inc Schiller Park, IL Hard 1.9 1.9 0% Facility confirmed emission estimate

Anoplate Corp Syracuse, NY Anodizing 0.72 0 100% Facility has no emissions from anodizing line

BIC Corp Milford, CT Hard 2.0 0 100% Facility no longer processes chromium, nor any plating

Birken Mfg. Co. Bloomfield, CT Hard 2.0 0 100% Facility is closed

Boeing

Commercial

Airplane Group Wichita, KS Hard 3.22 0 100% Facility scheduled to close in 2013

Borden St Louis, MO Hard 2.1 0 100% Facility is closed

Briggs & Stratton Popular Bluff, MO Hard 2.1 0 100% Facility has not processed hard chrome since 2000

Capital

Electroplating Houston, TX Hard 0.39 0 100% Facility decommisioned chrome plating tanks in 1998,

moved out of city and is now only a machine shop

### C & G Aircraft Ferris, TX Hard 2.2 0 100% Facility closed in 2008

CMP Anodizing

Corp Elk Grove, IL Hard 2.3 2.3 0% Facility confirmed emission estimate

Co-Operative

Plating St. Paul, MN Decorative 0.154 0 100% Facility switched to trivalent chromium

The Crown Group Portland, TN Hard 1.7 0 100% Facility no longer does hard chrome, only phosphating

Danbury Metal

Finishing Danbury, CT Hard 2.4 0.24 90% Revised data provided by facility, facility is very small and

buys only small amounts of chromium

Delstar Metal

Finishing Houston, TX Hard 2.5 0 100% Facility has never processed hard chrome

DOE KC Allied

Signal Kansas City, MO Hard 2.5 0 100% Facility does not process hard chrome

Dolloff Industries,

Inc Cleveland, OH Hard 0.68 0 100% Facility is closed

Engine

Components San Antonio, TX Hard 2.7 0 100% Facility no longer processes chromium, only silicon nickel

Fanning Electric

Plating Sherman, TX Hard 0.74 0.032 96% Revised data provided by facility

Feldkircher Wire

Fabricating Co. Hartsville, TN Hard 0.78 0 100% Facility is closed

Fusion, Inc. Houston, TX Hard 2.8 0 100% Facility decommissioned hard chrome plating in January

1995

GE Engine Services Dallas, TX Hard 2.8 0 100% Facility's hard chrome plating operation is closed

### Griep, Inc, Tri-City

Plating Beloit, WI Hard 2.9 0 100% Facility is closed

Guild Platers, Inc. Long Island City, NY Hard 3 0 100% Facility is closed

Gull Industries

(Cochran St.) Houston, TX Decorative 0.027 0.003 89% Revised data provided by facility

Gull Industries

(Cochran St.) Houston, TX Decorative 0.027 0.003 89% Revised data provided by facility

Hard Chrome Evansville, IN Hard 1.3 0 100% Facility is closed

HBM Co Lansing, IL Hard 3.2 0.348 89% Revised data provided by facility

Hiawatha

Metalcraft Minneapolis, MN Hard 0.56 0 100% Facility never processed hard chrome and had only

processed chromic acid anodizing, but not since 2008

Hi-Tech Chrome

Plating & Polishing

Co North Windham, CT Hard 3.3 0.3 91% Facility is very small with only two employees and

processes only very small amounts of chromium

Hi-Tech Metal

Finishing Denton, TX Hard 3.4 0 100% Facility no longer processes hard chrome

H & M Plating Co. Houston, TX Hard 3 0.32 89% Revised data provided by facility

Hoffman Plating

Company Cleveland, OH Hard 0.57 0 100% Facility is closed

Houston Mfg &

Speciality Houston, TX Hard 3.4 0 100% Facility decomissioned hard chrome tank 8 years ago

Hytek Finishes Kent, WA Hard 1.37 0.224 84% Revised data provided by facility

### Indianhead Plating Chippewa Falls, WI Anodizing 0.097 0 100% No anodizing process

Industrial Chrome

Plate San Antonio, TX Hard 3.7 0 100% Facility moved location and installed hooded tank system

with zero emissions

Industrial Hard

Chrome Newark, NJ Hard 3.27 1 73% Revised data provided by facility

Kilburn Plating Co Adamsville, TN Hard 0.79 0 100% Facility is closed

Lane Plating Dallas, TX Hard 4 0.353 91% Revised data provided by facility

Lincoln Plating Lincoln, NE Hard 4.1 1.03 75% Revised data provided by facility

Macs Plating

Works Tulsa, OK Hard 4.2 0 100% Facility is closed

Marine Corps

Logistics Base Albany, GA Hard 4.2 0 100% Facility no longer does chrome plating

Masterson

Industries, Inc. Round Rock, TX Hard 0.77 0.03 96% Revised data provided by facility

Mendoza Meatal

Coating Andrews, TX Hard 0.92 0 100% Facility is closed

Metal Finishing

Corp. Grand Prairie, TX Hard 4.4 0 100% Facility changed name over 4 years ago and has never

processed hard chrome

Metalplate &

Products Milwaukee, WI Hard 0.95 0 100% Facility is closed (since 2009)

Metokite Corp Lebanon, TN Hard 1.1 0 100% Facility no longer does hard chrome, only phosphating

### Minnesota Rubber St. Louis Park, MN Hard 1.0 0 100% Facility is closed and has not processed hard chrome for

more than 8 years

Mirror Industries Houston, TX Hard 0.8 0.03 96% Revised data provided by facility

National

Chromium Co, Inc Woonsocket, RI Hard 1.2 0 100% Facility is closed

NEO Industries Decatur, AL Hard 1.27 0.973 23% Revised data provided by facility

NEO Industries Portage, IN Hard 3.09 2.438 21% Revised data provided by facility

NEO Industries Beaver Dam, KY Hard 0.431 0.088 80% Revised data provided by facility

NEO Industries Weirton, WV Hard 1.15 0.006 99% Revised data provided by facility

Nuclear Plating Inc Cleveland, OH Hard 0.92 0 100% Facility is closed

Nussmeier

Engraving Evansille, IN Hard 1.9 0 100% Facility is closed

Oshkosh Plating

Serrvices, Inc. Oshkosh, WI Hard 1.2 0 100% Faciity no longer processing hard chrome, only zinc and

chromating

Perfection Plating

Inc. Nashville, TN Hard 1.2 0.12 92% Very small facility, revised data

Pitney Bowes Stamford, CT Hard 5.1 0 100% Facility no longer processes hard chrome, nor performs

any plating

Plastic Plate Inc. Grand Rapids, MI Hard 1.2 0 100% Facility only processes decorative chrome, but is closing

for refurbishing

### Poly-Metal

Finishing Inc Springfield, MA Hard 1.7 0 100% Facility no longer processes hard chrome, only anodizing

and chromating

Precision

Engineering Seattle Hard 1.4 0 100% Facility is closed (August 2004)

Precision Finishing

Inc. Sellersville, PA Hard 1.4 0 100% Facility has never processed hard chrome and has not

performed any plating since 1965

Precision Hard

Chrome Canton, OH Hard 5.2 0 100% Facility was closed when United Hard Chrome bought the

company

Precision Plating

Corp Vernon, CT Hard 1.4 0.14 90% Facility is very small, a one-man operation and only buys

minimal amounts of chromium each year

Premier Turbines Neosho, MO Hard 1.1 0 100% Facility no longer processes hard chrome

Progressive Plating

Co Indianapolis, IN Hard 5.6 0 100% Facility no longer processes hard chrome, only zinc plating

Quebecor Printing Mt. Morris, IL Hard 5.7 0 100% Facility no longer processes hard chrome

Remmington

Products Co. LLC Brideport, CT Hard 1.2 0 100% Facility is closed

Renfrow Hard

Chrome Co. Lubbock, TX Hard 1.2 0 100% Facility has only one tank with no stack and no emissions

from the facility

Rhimco Industries Mansfield, TX Hard 1.7 0 100% Facility does not have hard chrome plating and has never

had hard chrome

Rolls-Royce

Corporation Indianapolis, IN Hard 1.1 0 100% Facility no longer processes hard chrome

Roll Service, Inc Glenwood, IL Hard 1.3 0 100% Facility is closed

### Royal Plating &

Polishing Co. Pittsfield, MA Hard 1.3 0 100% Facility does not process hard chrome, only a very small

amount of decorative

R & R Machine China Springs, TX Hard 6 0.946 84% Revised data provided by facility, facility only has one hard

chrome tank with KCH CMP system and estimate

represents worst case scenario

Sandy's Bumpers

Mart Syracuse, NY Hard 1.8 0.18 90% Facility is very small and does not process hard chrome,

only decorative chromium

Saueressig Jackson, MO Hard 1.4 0 100% Facility is closed

Schumacher Co.

Inc. Houston, TX Hard 6.4 2.376 63% Revised data provided by facility

Seidel Inc Waterbury, CT Hard 1.4 0 100% Facility no longer processes any chromium

Sikorsky Aircraft Stratford, CT Hard 1.4 0 100% Facility do not process any chromium, nor conduct any

plating operations

SK Williams Co Wauwatosa, WI Hard 6.9 0 100% Facility is closed (since 2006)

S & K Industries Tulsa, OK Hard 1.3 0 100% Facility is closed

Snap-On Tools Johnson City, TN Hard 2 0 100% Facility is closed

Southern

Aluminum

Finishing Atlanta, GA Hard 2.1 0 100% Facility has never processed hard chrome, does anodizing,

but not chromic acid anodizing

Southern Graphics St. Louis, MO Hard 1.5 0 100% Facility no longer processes hard chrome

Southern Hard

Chrome Plating Spartanburg, SC Hard 7.2 0 100% Facility is closed (since 2005)

### South Shore

Plating Company Quincy, MA Hard 1.5 0 100% Facility does not process hard chrome, only a very small

amount of decorative

Southwest Plating

Company Bridgeview, IL Hard 2 0 100% Facility is closed

Speciality Plating Mt. Vernon, WA Hard 1.3 0.13 90% Facility does not process hard chrome, only decorative

chromium

Springfield

Electroplating Springfield, VT Hard 1.6 0.16 90% Facility is very small and processes only small amounts of

chromium, primarily EN

SPX Service

Solutions Owatonna, MN Hard 2.2 0 100% Facility does not process any hard chrome

SR of TN Ripley, TN Hard 1.2 0.12 90% Facility no longer does hard chrome, only decorative

chromium

Standard Plating

Co. Milwaukee, WI Hard 2.2 0 100% Facility is closed (since 2007)

Standard Aero San Antonio, TX Hard 1.6 0.21 87% Revised data provided by facility

Standard Plating

Inc. West Springfield, MA Hard 1.7 0 100% Facility is closed

Stanley Tools Div New Britain hard 1.5 0 100% Facility is closed and no longer proceses any chromium

State Plating LLC Elwood, IN Hard 2.3 0 100% Facility is closed (since 2007)

Superior Metal

Finishing Tualatin, OR Hard 7.9 0 100% Facility has never processed hard chrome and stopped

processing decorative chromium in late 1980's

Superior Plating

Inc. Minneapolis, MN Hard 1.7 0 100% Facility closed in December 2011

### Supreme Bumpers

Inc Toledo, OH Hard 2.4 0 100% Facility is closed

Surface Finishing

Technologies Elmira, NY Hard 8.2 0.295 96% EPA was using data from 1980’s before MACT controls

were installed, revised data was submitted to state in

1997

Surftech Finishes Kent, WA Hard 2.5 0 100% Facility is closed (June 2003)

Surgichrome Inc. Clackamas, OR Hard 1.6 0 100% Faclity is closed -- burned downed

Tech Industries Woonsocket, RI Hard 1.6 0 100% Facility is closed, burned to the ground

Tenneco

Automotive Cozad, NE Hard 9.3 0 100% Facility scheduled to close July 2012

Tenth Street

Industries Plano, TX Hard 1.6 0 100% Facility is closed

Texas Hydraulics

BDA Precise Hard

Chrome Waco, TX Hard 1.9 1.9 0% Facility confirmed emission estimate

TMT Industries Inc. Rochelle, IL Hard 2 0 100% Facility is closed

Torrington Co Torrington, CT Hard 2.1 0 100% Facility is closed

Triple Plate

Chrome Spokanne, WA Hard 1.8 0.18 90% Facility does not process hard chrome and only decorative

chromium

Truelove &

MaClean Warterbury, CT Hard 2.1 0 100% Facility no longer processes any chromium

Turbine Chrome

Services Houston, TX Hard 2.2 0 100% Facility is closed

### TWA Kansas City, MO Hard 2.3 0 100% American Airlines bought bankrupt TWA in 2001 and

operated facility until it closed in 2010

Tyco Valves &

Controls Harlingen, TX Hard 2.1 0 100% Facility no longer processes hard chrome, but has

decorative chrome that is exclusively trivalent (since 2007)

U.S. Polestar

Marine

Engineering Houston, TX Hard 2.8 0 100% Facility no longer at the location

Utility Platers, Inc. Kingston, NY Hard 3.1 0 100% Facility is closed

Val-Kro Inc. North Tonawanda, NY Hard 11.4 0 100% Facility is no longer processing chromium

Van der Houst,

USA Corp Terrell, TX Hard 3.0 0 100% Facility has been closed for 5 years

Vision-Ease lens Ramsey, MN Hard 1.8 0.1 94% Facility has small 19 gallon tank and revised data provided

by the facility

Vought Aircraft Dallas, TX Hard 12.6 0 100% Facility now owned by Triumph and has no hard chrome

plating

Warsaw Plating

Works Warsaw, IN Hard 3.9 0 100% Facility is closed

Weatherford

Aerospace Weatherford, TX Hard 4.1 0 100% Facility is no longer processing chromium

Wearmaster Kennedale, TX Hard 1.8 0 100% Facility has never processed hard chrome, now HVOF

Wesco Valve &

Mfg. Co Marshall, TX Hard 3.4 0 100% Facility decomissioned hard chrome tank over 10 years

ago

Wilson

Electroplating Binghamton, NY Hard 6.3 0 100% Facility is no longer processing chromium

### Wilson

Manufacturing Green Park, MO Hard 4.5 0 100% Facility no longer does hard chrome

Woodhill Plating

Co. Cleveland, OH Decorative 0.21 0 100% Facility only processes trivalent chrmium

TOTALS 325.346 19.200 94%

(306.146 lbs.)

### 3233 G ANO 

### S TREET 

### • H OUSTON



### , TX 77009

- 6398 • T EL 

### (713) 224

- 2430 • F AX 

### (713) 224

- 9256

P RESIDENT



### J. K ELLY 

### M OWRY



### 3233 G ANO 

### S TREET



### H OUSTON



### , TX 77009

T EL



### . (713) 224

- 2430

C ELL 

### (713) 816

- 3479

F AX



### . (713) 224

- 9256

jkelly@gullindustries.com 

## March 20, 2012

TO: J eff Hannapel, The Policy Group

FM: J

. K elly Mowry

RE: PFOS Alternative Test/Fail

- Gull Industries, Inc

Dear Jeff;

Per our recent conversation, I’ve put together the following for your review. I’ll make this a quick

and to the point report and keep my supplier somewhat protected but if you need more details, I’ll gladly

provide them.

On July 23, 2010, well in advance of EPA’s deadline to eliminate PFOS from the market place,

we began experimenting with a non

- PFOS fume suppressant. The test was conducted on a production

Armoloy bath at our facility which is a proprietary 54 ounce per gallon chrome 6, TDC bath with a

redundant MAPCO mesh pad mist elimination system and existing PFOS fume suppressant in place.

As the t est began, no anomalies were noted other than in increase in the amount of non

- PFOS agent

needed to maintain our surface tension as well as the timing of the adds and the testing needed. We

continued the test with what seemed like successful results throu gh 9/13/2010 when we tested for PFOS

in our effluent and found that number to be 11, 500ppt and used that as our base line. On 5/11/11 we

changed to a slightly different formula that had a little more foaming agent in it and after seeing little

difference in performance and an increase in the amount of product needed, changed back to the

original , non

- PFOS formula on 6/29/11.

During this period, we also conducted our regularly scheduled PEL testing and found that while

we were still within OSHA limits, our measured PEL had risen almost an order of magnitude and while

we could not confirm it was a result of the non

- PFOS change, it was the only factor in our operation that

had been altered. We repeated the test, insured all other aspects were perfect and found similar results.

At our 6 month point, we again sampled for PFOS in our effluent and found that it was all but gone...we

were PFOS free !

Unfortunately on September 19 th 

## , 2011, the non

- PFOS product seemed to ‘fall apart’ chemically.

Our surface tensi on rose rapidly and uncontrollably. We began smelling ‘chromic smells’ in the plant and

within minutes, shut our entire operation down. Not only did we smell chrome, the product seemed to

become suspended and airborne coming down onto flat surfaces in th e plant. After two days of zero

production due to the threat of risk to our staff, the non

- PFOS product was replaced and we resumed

running with a PFOS surface tension product. We quickly regained our surface tension numbers a s well

as our clean air work environment

. Once in place and ‘stable’, our non

- PFOS additive required approximately twice the amount of

product to maintain ‘ less than ’ our desired surface tension (we could never achieve the same low surface

tension numbers) . It required us more th an double the amount of time to make adds (as they were

needed more frequently) and with that, it required more than double the amount of time to test the bath.

As the product neared what would eventually be its point of self destruction, we were adding a s much as

4

- 5x of the product to maintain a less than desired surface tension and then when it failed entirely, it shut

our operation down completely. Effected were profit centers that ranged from several hundred to several

thousands of dollars per hour a nd again, all profit centers were closed for 2 operating days. Most

importantly though, had we continued to operate, our staff’s health and safety may have been

compromised.

## Copies of test data taken during non

- PFOS test period:

SURFACE TENSION READINGS

– continued Page 8

Plant 1

- Plant 2

HCA 8.1 13308671 46587215

8/23/2010 Test Begins 25 9 32oz 10763 32 0 0oz 0 jkm

13311483

8/24/2010 26.5 9 281 2 #VALUE! jkm

13316537

8/25/2010 27.5 9 5054 #VALUE! jkm

13318281

8/26/2010 27.5 9 1744 #VALUE! jkm

13321812

8/27/2010 28 9 3531 #VALUE! jkm

13323451

8/30/2010 26.5 9 32oz 1639 #VALUE! jkm

13325979

8/31/2010 27 9 2528 #VALUE! jkm

13328192

9 /1/2010 27 9 2213 #VALUE! jkm

13331850

9/2/2010 27.5 9 3658 #VALUE! jkm

13334820

9/3/2010 27.5 9 2970 #VALUE! jkm

13336221

9/7/2010 27 9 32oz 1401 #VALUE! jkm

13339004

9/8/2010 28 9 2783 #VALUE! jkm

13342971

9/9/2010 27 9 3967 #VALUE! jkm

133470 10

9/10/2010 27.5 9 4039 #VALUE! jkm

SURFACE TENSION READINGS

Plant 1

- Plant 2 Pg 9

Ramiro Gull Industries/Armoloy of Texas

Veron RO=70.5 dynes

Ma tias TAP=.... (or 72) TAP=78.0 dynes 2/06/08

Recommended dynes / cm 28

- 32

Date Standard Plant 1 AmpHrs/ Plant 2 AmpHrs/

(RO Water) Tank 1 Adds HrsFmLst Tank 1 Adds HrsFmLst

70.5 dynes Ti me (oz) Add Time (oz) Add By: (Init)

HCA 8.1 Testing 13348275

9/13/2010 Continues 28 9 16oz 1265 jkm PFOS 11

13348289

9/14/2010 29 9 14 #VALUE! jkm

13360324

9/15/2010 28 9 12035 #VALUE! jkm13363491

9/16/2010 No anomalies 28 9 3167 #VALUE! jkm

found in bath 13369734

9/20/2010 26 9 16oz 6243 #VALUE! jkm

13372254

9/21/2010 26.5 9 2520 #VALUE! jkm

13376332

9/22/2010 29 9 4078 #VALUE! jkm

13380915

9/23 /2010 29 9 4583 #VALUE! jkm

13388857

9/27/2010 28 9 7942 #VALUE! jkm

13392792

9/28/2010 29.5 9 16oz 3935 #VALUE! jkm

13413975

10/1/2010 27.5 9 21183 #VALUE! jkm

13416214

10/4/2010 28 9 16oz 2239 #VALUE! jkm

13432485

10/8/2010 28 9 16271 #VALUE! jkm

13433900

10/11/2010 29 9 16oz 1415 #VALUE! jkm

13474719

10/22/2010 27 9 16oz 40819 #VALUE! jkm

13489633 46587215

10/29/2010 28.5 9 16oz 149 14 #VALUE! jkm

13498114 46640246

11/3/2010 26 9 16oz 8481 29 0oz 53031 jkm

13519680

11/10/2010 27.5 9 16oz 21566 #VALUE! jkm

13545569

11/19/2010 28 9 16oz 25889 #VALUE! jkm

SURFACE TENSION READINGS

Plant 1

- Plant 2 Pg 10

Ramiro Gull Industries/Armoloy of Texas

Veron RO=70.5 dynes

Matias TAP=.... (or 72) TAP=78.0 dynes 2/06/08

Recommended dynes / cm 28

- 32

Date Standard Plant 1 AmpHrs/ Plant 2 AmpHrs/

(RO Water) Tank 1 Adds HrsFmLst Tank 1 Adds HrsFmLst

70.5 dynes Time (oz) Ad d Time (oz) Add By: (Init)

HCA 8.1 Testing 13560387

11/22/2010 Continues 28 9 16oz 14818 jkm

13587175

12/2/2010 26 9 16oz 26788 #VALUE! jkm

136120 13

12/6/2010 29 9 16oz 24838 #VALUE! jkm

13630511

12/13/2010 No anomalies 27 9 16oz 18498 #VALUE! jkm

found in bath 136842961/5/2011 29 9 16oz 537 85 #VALUE! jkm

13695506

1/12/2011 28 9 16oz 11210 #VALUE! jkm

13719666

1/21/2011 28 9 16oz 24160 #VALUE! jkm

13730563

1/24/2 011 28 9 16oz 10897 #VALUE! jkm

13755404

1/31/2011 26 9 16oz 24841 #VALUE! jkm

13780701

2/9/2011 28.5 9 16oz 25297 #VALUE! jkm

137921 85

2/16/2011 25 9 16oz 11484 #VALUE! jkm

13816663

2/23/2011 27 9 16oz 24478 #VALUE! jkm

13832515

3/2/2011 27.5 9 16oz 15852 #VALUE! jkm

13855165

3/9/2011 27.5 9 16oz 22650 #VALUE! jkm

13877310

3/16/2011 28 9 16oz 22145 #VALUE! jkm

13898201

3/16/2011 29 9 16oz 2 0891 #VALUE! jkm

13944007

4/6/2011 27 9 16oz 45806 #VALUE! jkm

13973640

4/13/2011 27 9 16oz 29633 #VALUE! jkm

13997128

4/20/ 2011 28 9 16oz 23488 #VALUE! jkm

5/3/2011 27 16 14047905 30 0 46651561

SURFACE TENSION READINGS

Plant 1

- Plant 2 Pg 11

Ramiro Gull Industries/Armoloy of Texas

Veron RO=70.5 dynes

Matias TAP=.... (or 72) TAP=78.0 dynes 2/06/08

Recommended dynes / cm 28

- 32

Date Standard Plant 1 AmpHrs/ Plant 2 AmpHrs/

(RO Water) Tank 1 Adds HrsFmLst Tank 1 Adds HrsFm Lst

70.5 dynes Time (oz) Add Time (oz) Add By: (Init)

New Formula 14066984 46657356

5/11/2011 More Foaming 29 9 16oz 19079 28 9 0oz jkm

Slightly lrgr adds 14089231

5/19/2011 32 9 16oz 22247 #VALUE! jkm

14109414

5/25/2011 32 9 16oz 20183 #VALUE! jkm

14128564

6/1/2011 32 9 16oz 19150 #VALUE! jkm

14173901

6/15/2011 33 9 24oz 45337 #VALUE! jkm

141940846/22/2011 35 9 24oz 20183 #VALUE! jkm

Switched back to 14212831

6/29/2011 HCA 8.1 33 9 24oz 18747 #VALUE! jkm

(Orig.Formula) 14251072

7/13/2011 29 9 48oz 38241 #VALUE! jkm

14276555

7/22/2011 31 9 16oz 25483 #VALUE! jkm

14292291

7 /27/2011 29 9 24oz 15736 #VALUE! jkm

14336599

8/10/2011 32 9 32oz 44308 #VALUE! jkm

14378379

8/24/2011 33 9 32oz 41780 #VALUE! jkm

14 401218

8/31/2011 31.5 9 24oz 22839 #VALUE! jkm

14420499

9/7/2011 34 9 24oz 19281 #VALUE! jkm

14445426

9/14/2011 39 9 24oz 24927 #VALUE! j km

C HROME SMELL 14462751

9/19/2011 DETECTED 49 9 54oz 17325 #VALUE! J km

14463640

9/20/2011 44 9 0oz 889 #VALUE! jkm

CHANGE TO 14463640 Change

9/20/2011 HCA6.2 31 9 1QT 0 #VALUE! jkm produc

14467740

9/21/2011 32 9 0oz 4100 #VALUE! jkm

30 0 46651561

NOTE: We do not demonstrate compliance by u se of fume suppressants but instead through control equipment. jkm