Ms. Ann Roarke
Precision Golf Corporation
535 Migeon Avenue
P.O. Box 298
Torrington, Connecticut 06790

Dear Ms. Roarke:

On October 7, 1997, the U.S. Environmental Protection Agency (EPA) received a letter from Precision Golf Manufacturing Corporation (Precision Golf) with questions regarding initial performance testing required by 40 CFR Part 63, Section 63.343. Specifically, Precision Golf would like written confirmation that it qualifies for exemption from the initial performance testing requirements.

An owner or operator of an affected source which meets all the criteria specified under Section 63.343(b)(2) is not required to conduct an initial performance test. You have informed EPA that Precision Golf operates a source which meets all the criteria identified in Section 63.343(b)(2). Specifically, the source is a decorative chromium electroplating tank which uses a wetting agent to inhibit chromium emissions, and the facility complies with the applicable surface tension limit of 45 dynes/cm as demonstrated through continuous compliance monitoring required under Section 63.343(c)(5)(ii). In addition, Precision Golf also employs a composite mesh pad add-on control technology.

Based on the information you have provided, Precision Golf qualifies for an exemption from initial performance testing so long as it meets the criteria specified in Section 63.343(b)(2) even though it operates an additional measure of control. In a Notification of Compliance Status to EPA dated January 23, 1997, Precision Golf notified EPA that it will demonstrate compliance with the surface tension limit of Section 63.342(d)(2) through continuous compliance monitoring of the surface tension limit. Please be aware that if Precision Golf elects to pursue another monitoring strategy to demonstrate compliance (e.g., pressure drop of control device), a performance test would be required to establish the appropriate parameter compliant values that correspond to the emission limit prior to implementing an alternate monitoring strategy. This is not required, however, as long as Precision Golf is monitoring and meeting the applicable surface tension limit as specified in the regulation.

If you have any further questions, please call Susan Lancey of my staff at (617) 565-3587.

Sincerely,

Gerald C. Potamis, P.E.
Manager, Air Permits Program

cc: Lou Santos, CT DEP