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From: Wolman, Marc (DEP) [Marc.Wolman@state.ma.us]

Sent: Tuesday, February 22, 2011 1:01 PM

To: Hancy, Cindy Wang

Subject: FW: Follow up - Cr Electroplating Information Request - US EPA

Attachments: MA Cr Electroplating plant list 2.7.11.xls

Hi Cindy

I reviewed our database for information on the facilities you listed and the information you requested.

Per our previous e‐mail exchanges, the SCCs you provided are not active in our inventory database.  We did search for

the alternative SCCs and identified two apparently active facilities with these SCCs in their records, but none of the

details you requested

I made some revisions to your “MA Cr Electroplating plant list” workbook, attached.

1. On the sheet with the facility list, I changed the font to strikethrough for those facilities that appear to be closed,

based on information in our inventory database.  The remaining facilities may still be operating.

I believe Karen already indicated that MassDEP does not take delegation of NESHAP, except as it may apply at a Title V

facility and appear as an applicable requirement in the Title V Permit ‐ not the case with most, if not all, the listed

facilities.  Therefore, little if any of the information you seek appears to be in the inventory records of these facilities.

Your best bet would be to contact the facilities directly.

Regards

Marc Wolman 

MassDEP 

(617) 292-5515 

From: Hancy, Cindy Wang [mailto:chancy@rti.org] 

Sent: Tuesday, February 08, 2011 3:10 PM 

To: Regas, Karen (DEP) 

Cc: Marinshaw, Richard 

Subject: Follow up - Cr Electroplating Information Request - US EPA 

Karen,

Thank you for speaking with me today. As I explained in our conversation, the U.S. Environmental Protection Agency

(EPA), is performing the residual risk and technology review of the National Emission Standards for Hazardous Air

Pollutants:  Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (Chromium Electroplating

NESHAP).  Amendments to the NESHAP were proposed on October 21, 2010 (75 FR 65068), and EPA is under a court‐

ordered deadline to finalize the amendments by June 30, 2011.  Several comments received on the October 2010

proposal stated that EPA lacked adequate data to fully assess the risk associated with emissions from chromium

electroplating sources; other commenters stated that EPA did not account for the facilities with the highest risk.  In

response to those comments, EPA is now trying to collect data on potentially high risk facilities.  RTI International is
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assisting EPA in this effort by contacting several State agencies to request data on the 5 to 10 facilities in those States

that are likely to have the highest risk.

The facilities we are concerned with have the following classification codes:

NAICS: 332813

SCC: 3‐09‐010‐018, 3‐09‐010‐028, 3‐09‐010‐038

Attached are two files, one containing the facilities we have listed for MA, the other is a file that lists the specific types of

data needed, we would like to collect as many of the listed items as possible for each facility.  The most critical data

needs are:   

For each chromium electroplating or anodizing tank:

 Type of chromium electroplating process (hard, decorative, trivalent, anodizing)

 Surface dimensions (length and width)

 Rectifier capacity (amperes)

 Limits on rectifier operation (ampere‐hours per year)

 Maximum permitted process operating hours (hours per year)

 Typical process operating hours (hours per year)

 Emission control method

 Emission test data (complete test report, if available)

 Any updates to Cr. Electroplating facilities listed in the attachment (plant closings, etc.)

In order to remodel risk for this source category and re‐evaluate the regulatory options for reducing risk to acceptable

levels, while meeting the June 30, 2011 deadline, we would like to obtain the requested information as soon as possible,

and no later than the end of February 2011.

If you have any questions about this request or would like to discuss any issues related to the Chromium Electroplating

NESHAP, you can contact Phil Mulrine with EPA's Office of Air Quality Planning and Standards.  Phil can be reached by

phone at:  919‐541‐5289, or by email at:  mulrine.phil@epa.gov.

Thanks again for your help, and I look forward to talking to you soon.

Cindy Wang Hancy

RTI International

P.O. Box 12194

Research Triangle Park, NC 27709

Phone:  (919) 541‐6623

Fax:  (919) 316‐3420