### ILLINOIS

"Buzz Asselmeier"

<Buzz.Asselmeier@illinois.gov>

08/15/2007 11:36 AM

Re: Fw: RTR

-- Emissions Estimates for Chromium Electroplating



### Everything looks ok to me. As a side note, Gravure Process Co shut down its operations

on March 12, 2007.

-----------------------------------------------------

David 'Buzz' Asselmeier

Illinois EPA

Phone: 217

- 782

- 0285

FAX: 217

- 782

- 6348

e

- mail: buzz.asselmeier@illinois.gov

### OHIO

"Tom Velalis" <tom.velalis@epa.state.oh.us>

08 /15/2007 11:57 AM

Re: Fw: RTR

-- Emissions Estimates for Chromium Electroplating



### Suzanne

Thanks for the opportunity to comment. EPA is re

- working the Chromium

emissions for three out of the four Ohio's facilities. It seems that those facilitie s

used the AP

- 42 emission factor and resulted in an overestimate of emissions.

Since the change is applied to all facilities in the country, I will have no problem with

the revision. However, it will be a good idea to revise the AP

- 42 section and

the We bFire emission factor for Chromium, so as to avoid repeat bad facility

estimates in the future.

Have a nice afternoon Suzanne.

Tom V.

### WISCONSIN

"Patterson, Ralph C

- DNR"

<Ralph.Patterson@Wisconsin.gov>

08/17/2007 11:24 AM

RE: RTR

-- Emissions Estimates for Chromium Electroplating

Hi Suzanne,

We looked at your numbers for Scot Industries and think they are a

little high. As proof, I am sending you the Scot Industries reported

numbers for insoluble and soluble chromium as reported from 1999

- 2005.

Let me know if you need anything else.

Ralph

FacID LastOfLastOfFacName SIC Pollutant 1999_lbs 2000_lbs

122049950 Scot Industries 3471 CHROMIUMVI I 3.4565 2.876

122049950 Scot Indust ries 3471 CHROMIUMVI S 0.5805 0.5805

2001_lbs 2002_lbs 2003_lbs 2004_lbs 2005_lbs

1.3312 7.5003 4.6266 2.871780331 2.909173131

0.8058 1.2093 0.6552 0.72955405 0.544869738

### MICHIGAN

"Dennis McGeen" <mcgeendd@michigan.gov>

08/17/2007 10:58 AM

Re: Fw: RTR

-- Emissions Estimates for Chromium Electroplating

Suzanne, the facility contact was able to pull up some info at the

plant and confirmed that for each year since 1999 the throughput data

has been overestimated by a factor of 1000, due to confusion over AMP

HR vs. E3AMP

- HR. He will submit revised throughput data early next

week to confirm the changes for each year, but in the meantime EPA

staff can take the chromium values for Norbrook Plating and divide by

1000

.

Dennis

"Dennis McGeen" <mcgeendd@michigan.gov>

08/17/2007 09:34 AM

Re: Fw: RTR

-- Emissions Estimates for Chromium Electroplating

I talked with the facility contact this morning and he will review the

data this weekend (his files are at home). I sent him some MAERS

summary reports to assist him. Hopefully by Monday morning we'll have

the issue resolved. I'm 95% certain that the problem is related to the

unit codes and that the emissions and throughput are overestimated by a

factor of 1 000. Wouldn't be the first time this has happened in a

facility's MAERS submittal!

Dennis

"Dennis McGeen" <mcgeendd@michigan.gov>

08/16/2007 02:11 PM

Re: Fw: RTR

-- Emissions Estimates for Chromium ElectroplatingYou're welcome! The MAERS c ontact for Norbrook Plating will give me a

call tomorrow morning. The person who took my call was fairly

knowledgeable and said there probably was an error in the MAERS

reporting if the chromium emissions appeared high; she said their

facility performs ai r sampling each year to comply with state or

federal regulations and has always been well within acceptable levels.

"Dennis McGeen" <mcgeendd@michigan.gov>

08/16/2007 09:36 AM

Re: Fw: RTR

-- Emissions Estimates for Chromium Electroplating

I'm a waiting a response from district staff on B6660, Norbrook Plating.

However, I would like to comment that the throughput data for Norbrook

Plating for most years was one to two orders of magnitude higher than

any of the other chrome plating facilities in M ichigan which made the

list. This makes it seem more likely that a unit code error may be

involved in the high levels of chromium reported by this facility.

Here are my comments on the other three chromium electroplating

facilities which were in Table 1 of the EPA list.

A8830, Chrome Craft Corp. In the 2002 EI, 3.80 lbs of Chromium VI were

reported with emission basis as "Other". In 2006, the facility

reported 3.80 lbs of Chromium (not Chromium VI), with emission basis

listed as "Other". I don't have access to the calculations used for

their emission estimation but the results seem within the realm of

credibility. EPA noted that there was no basis for changing their 2002

emissions in the NEI but that the estimate was likely to be high.

N1863, Deco'Pl ate Mfg. Company

- The MAERS emission estimator estimated

919 lbs of Chromium VI in the 2002 NEI, using a standard emission

factor. In the 2006 EI, the facility estimated 0.56 lbs of Chromium

VI, listing emission basis as "Other". I don't have access to the

calculations, but this is within the same ballpark as EPA's 2002

estimate for Deco'Plate of 1.27 lbs.

N6362, Armorclad Inc.

- The MAERS emission estimator estimated 44.97

lbs of Chromium VI in the 2002 NEI, using a standard emission factor;

EPA noted that this was likely to be high but did not have a basis for

changing the estimate. In the 2006 EI, the facility reported 0.03 lbs

of Chromium based on a stack test. Also in the 2006 EI, the MAERS

emission estimator estimated 0.44 lbs of Chromium VI, usi ng the same

emission factor as in previous years but with the application of a

99.00% control efficiency which the facility had reported for PM10

Primary. This submittal was not audited by district staff.

Dennis"Dennis McGeen" <mcgeendd@michigan.gov>

08/15/2007 03:27 PM

Re: Fw: RTR

-- Emissions Estimates for Chromium Electroplating (SRN# B6660, Norbrook Plating)

Suzanne,

Regarding the substantial maximum individual lifetime cancer risk (MIR)

of 6,000 in one million estimated by EPA modeli ng for the Norbrook

Plating facility (SRN# B6660) in Warren, I've left a voice mail message

for the district staff person assigned to this facility. It appears

that he will be in the office tomorrow.

From my review of the Chromium VI emissions data for 2000 through 2006,

I see that Norbrook Plating's throughput decreased by three orders of

magnitude in 2004 then bounced back to former levels in 2005 and 2006,

which suggests to me an error in throughput reporting. No Chromium VI

estimated for 2000 or 20 01. The MAERS emission estimator estimated

1060.65 lbs of Chromium VI in '02 and 1107.79 lbs in '03, and the

facility estimated 6.61 lbs in '04, 2885.68 lbs in '05 and 2922.68 lbs

in '06. It is quite possible that there is a unit code error in their

thr oughput reporting in several of the years (reporting under E3AMP

- HR

and thinking they were reporting under AMP

- HR, which would result in an

increase of three orders of magnitude). Maybe '04 was the year they

got it correct? No % control was reported by t he facility in any year

for the electroplating tank even though a control device (MIST

ELIM,MED) was listed, which may be part of the problem. Will keep you

posted.

Dennis