P.1 

OAR Box 1158 

Prepped by RyanDugan 

Document Number: 

42)I-C-18 

Docket Number: 

A-88-02 

Printed 4/28/2008 2:34:13 PM Sheet 42 of 349 
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USS J 

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"t PRO** 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 

A-88-02 

-X-C-.8 

MAY :QJ 

Mr. Stan Welch 

President 

Bronson Plating Company 

130 Industrial Avenue 

Bronson, Michigan 49028 

Dear Mr. Welch: 

•• . O .LAmr-"-—— \, M 

. krAi_D5c__i_] 

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As you may know, the United States Environmental Protection Agency 

(EPA) is considering adding chromium to the list of hazardous air 

pollutants under Section 112 of the Clean Air Act, as amended, August 1977. 

A preliminary assessment has identified 11 categories of stationary 

sources as potential emitters of significant quantities of chromium to 

the atmosphere. Included among these source categories is chromium 

electroplating. Because the preliminary assessment was based on limited 

data and available information, especially with respect to the quantities 

and forms of chromium actually emitted, EPA has undertaken a program to 

develop additional background information on all 11 source categories. 

This information will be used to determine the need for standards for 

each source category. 

We are requesting that Bronson Plating Company provide information 

on processes, emission levels, and emission control for its facility in 

Bronson, Michigan. The specific information requested is itemized in 

Enclosure 1. This information, along with similar information from 

other companies, will be used to assess the significance of chromium 

emissions from the chromium electroplating industry. We are sensitive 

to the amount of labor required to respond to this request and have 

tried to limit it to information necessary to define the current status 

of emission control. Also, you may merely respond "not applicable" +n 

questions that do not apply to your plant. 

to 

The authority for EPA's information gathering is included in 

Section 114 of the Clean Air Act, as amended (42 U.S.C. 7414). Enclosure 

of this authority. If you believe that disclosure of 

information you submit would reveal a trade secret, 

identify such pieces of information. Please do not 

response "confidential" if only certain portions consist 

information. Refer to Enclosure 2 for the information 

contains a summary 

specific pieces of 

you should clearly 

label an entire 

of trade secret 

EPA may require, at a later time, to support your confidentiality claims. 

Any information determined to constitute a trade secret will be protected 

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under 18 U.S.C. 1905. If no claim of confidentiality accompanies the 

information when it is received by EPA, it may be made available to the 

public by EPA without further notice (40 CFR Part 2.203, September 1, 

1976). All emission data, however, will be available to the public. It 

will simplify handling procedures if you would separate specific items 

claimed to be confidential from the balance of the data. 

The EPA has contracted with Midwest Research Institute (MRI) (Contract 

No. 68-02-3817) to obtain information pertinent to the industry. Thus, 

as noted in Enclosure 3, MRI has been designated by EPA as an authorized 

representative of the Agency. Therefore, MRI has the rights discussed 

above and in Enclosure 2. As a designated representative of the Agency, 

MRI is subject to the provisions of 42 U.S.C. 7414(c), respecting 

confidentiality of methods or processes entitled to protection as trade 

secrets. 

Enclosure 4 summarizes Agency and Emission Standards and Engineering 

Division policies and procedures for handling privileged information and 

describes EPA contractor commitments and procedures for use of confidential 

materials. It is EPA's policy that compliance by an authorized representative with the requirements detailed in Enclosure 4 provides sufficient 

protection for the rights of submitters of privileged information. 

If you have any questions regarding this request or are unable to 

provide me with responses to the enclosed questions by June 5, 1985, 

please contact Mr. Al Vervaert or Mr. James Crowder, of the Industrial 

Studies Branch, at (919) 541-5601. 

Sincerely, 

Jack R. Farmer 

Director 

Emission Standards and 

Engineering Division 

4 Enclosures 

J2. 
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Enclosure 1 

INFORMATION REQUEST FORM 

CHROMIUM PLATING—JOB SHOP 

Please provide answers to the following questions. Attach drawings 

wherever appropriate. If you believe that any of the information 

requested is confidential, please submit this information on a separate 

sheet marked "CONFIDENTIAL." 

Name and address of plant: 

Name and title of respondent: 

Telephone number of respondent: 

Date: 

A. General 

1. Plant location (UTM coordinates or latitude/longitude): 

2. Age of plant: 

3. Hours of operation: h/d d/wk wk/yr 

4. Processes performed at the plant: 

5. Type of products or items that receive chromium plate: 

6. Percent of net income generated by chromium plating: 

7. No. of chromium plating tanks at the plant: 

a£. 
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I 

B. 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

11. 

12. 

13. 

14. 

15. 

16. 

17. 

2 

Chromium Platinq Operation 

For each chromium plating tank, please provide the following 

information (cite typical values rather than ranges for operating and 

production parameters): 

Tank identification 

Manufacturer 

Date installed 

Type of platinq (e.q.. 

hard, decorative, 

etching, etc.) 

Automatic or manual dip 

Dimensions of tank 

(1 x w x d) , ft 

Tank capacity, gal 

Freeboard (i.e., 

distance from surface 

of solution to top of 

tank), in. 

Substrate plated (e.q., 

plastic, brass, etc.) 

Concentration of chromic 

acid, oz/gal 

Chromic acid usage, 

lb/mo 

Catalyst(s) used 

Concentration of 

catayst(s), oz/gal 

Temperature of platinq 

solution, °F 

Operatlnq voltage, 

volts 

Operatinq current, 

amperes 

Current density, 

amperes/ft' plated 

.,, 

/ 
•'• 

. 

18. 

19. 

20. 

21. 

22. 

23. 

24. 

C. 

3 

Surface area plated, 

ft /rack 

Thickness of chromium 

deposited, in. 

Platinq time, min/rack 

Hours of operation, h/d; 

d/wk; wk/yr 

Percent of operatinq 

time electrodes are 

energized 

Production rate, ft 

plated/yr 

Total ampere-hours for 

a typical year 

Emission Control System 

For the emission control system used on each chromium plating tank, 

please provide the following information: 

1. 

2. 

3. 

Tank identification 

(see Question B.l.) 

Demisting agent used 

a. Type (e.q., foam, 

plastic balls, 

etc.) 

b. Manufacturer 

c. Brand name 

d. Usaqe, lb/yr 

e. Estimated control 

efficiency, % 

f. Basis for estimate 

Emission capture system 

a. Manufacturer 

b. Model 

c. Type (e.q., side 

draft hoods, 

push-pull, etc.) 

d. Year of installation 

e. Size (1 x w) , ft 

f. Helqht above tank, 

in. 

q. Percent of tank 

surface area 

covered by hood 

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... , -,-| 

s 
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4. 

D. 

h. 

i. 

Emi 

a. 

b. 

c. 

d. 

e. 

f. 

g. 

h. 

1. 

j. 

k. 

Emi 

Estimated capture 

efficiency, % 

Basis for estimate 

ssion control device 

Manufacturer 

Model 

Type (e.g., packedbed scrubber, etc.) 

Year of installation 

Gas flow rate, scfm 

Actual 

Desiqn 

Inlet qas temperature, °F 

Type of liquid used 

for scrubbing 

L1quid-to-qas ratio 

Gas pressure drop 

across system, 

in. H20 

Control efficiency, % 

Actual 

Desiqn 

Destination of 

collected material 

ssions 

For each chromium plating tank, please provide estimates for both 

controlled and uncontrolled emissions, citing the basis for each 

estimate. If the estimates are based on actual test data, provide copies 

of all applicable test reports. Also, please provide information on any 

existing State emission limitations with which your plant must comply. 

1. Tank identification 

(see Question B.l.) 

2. Uncontrolled emissions, lb/h 

Particulate matter 

Total chromium 

Hexavalent chromium 

Basis for estimates 

3. Controlled emissions, lb/h 

Particulate matter 

Total chromium 

Hexavalent chromium 

Basis for estimates 

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4. State emission limitations, lb/h 

Particulate matter 

Total chromium 

Hexavalent chromium 

E. Stack Parameters 

Please provide a plan view of the plant, identifying each chromium 

plating tank or line and all stacks and other emission discharge points 

associated with the control devices listed in Section C. For each 

discharge point, please provide the following: 

1. Identification (as 

shown on plan view) 

2. Type (e.g., horizontal 

vent, vertical 

stack, etc.) 

3. Sources serviced 

4. Height above ground 

level, ft 

5. Inside diameter, in. 

6. Volumetric flow, acfm 

7. Gas temperature, °F 

F. Capital and Annualized Costs 

For the emission control system on each chromium plating tank, please 

provide the following cost information (Base year = ) : 

1. Tank indentification 

(see Question B.l.) 

2. Capital costs, $ 

a. Control device 

b. Hood 

c. Fan 

d. Ductwork 

e. Stack 

f. Installation fee 

g. Total 

3. Annualized costs t 

a. Capital recovery, 

$/yr 

Interest rate, % 

Depreciation life, 

yrs 

b. Electricity, $/yr 

Unit cost, $/kWh 

c. Water, $/yr 

Unit cost, 

$/l,000 gal 

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d. Maintenance, $/yr 

Labor, man-h/yr 

Materials, $/yr 

e. Demisting agent, $/yr 

Unit cost, $/lb 

f. Chromic acid 

recovery, $/yr 

Quantity of chromic 

acid recovered, 

lb/yr 

Unit value, $/lb 

g. Total 

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1 

IDENTICAL LETTER SENT TO THE FOLLOWING ADDRESSEES: 

1. Mr. Caryl McClarnon 

Plant Manager 

NEO Industries 

Gate City Industrial Centre 

Post Office Box M 615 

Gary, Indiana 46401 

Variable information: Page 1, paragraph 2, line 1: ".. . that NEO 

Industries provide . . ." Line 2: '' . . . for its facilities in Gary, 

Indiana, and Weirton, West Virginia." 

2. Mr. Allen Miller 

President 

Miller & Son 

24-T Belleville Avenue 

Belleville, New Jersey 07109 

Variable information: Page 1, paragraph 2, line 1: ".. . that 

Miller & Son provide . . ." Line 2: " . . . for its facility in Belleville, 

New Jersey." 

3. Mr. William Logozzo 

President 

Nutmeg Chrome Corporation 

111 Vanderbilt Avenue 

West Hartford, Connecticut 06110 

Variable information: Page 1, paragraph 2, line 1: ".. . that 

Nutmeg Chrome Corporation provide . . ." Line 2: " . . . for its facility 

in West Hartford, Connecticut." 

4. Mr. Peter Faxon 

President 

Multichrome Company, 

Incorporated 

1100 Mercantile Street 

Oxnard, California 93030 

Variable information: Page 1, paragraph 2, line 1: ".. . that 

Multichrome Company, Incorporated, provide . . ." Line 2: ".. . for its 

facilities in Oxnard, California, and Los Angeles, California." 

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5. Mr. Bill Moore 

Corporate Vice President 

Electro-Coatings, Incorporated 

1605 School Street 

Moraga, California 94556 

Variable information: Page 1, paragraph 2, line 1: " . . 

Electro-Coatings, Incorporated, provide . . ." LineTT " . . . 

of its facilities." 

that 

for all 

Mr. W. G. Home, Jr. 

Vice President 

Empire Hard Chrome, Incorporated 

1615 South Kostner Avenue 

Chicago, Illinois 60623 

Variable information: Page 1, paragraph 2, line 1: 

Empire Hard Chrome, Incorporated, provide . . . Line 2 

facility in Chicago, Illinois." 

that 

for its 

Mr. Ken Kohlmann 

Superintendent 

Jagemann Plating Company 

1324 South 26th Street 

Manitowoc, Wisconsin 54220 

Variable information: Page 1, paragraph 2, line 1: ".. . that 

Jagemann Plating Company provide . . ." Line 2: " . . . for its facility 

in Manitowoc, Wisconsin." 

/£> 
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Docket No. A-88-02 

Subcategory I-C 

Enclosures 2, 3, and 4 of this document are 

identical to enclosures 1, 2, and 3 in docket item 

No. I-C-l. 

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