MEMORANDUM

SUBJECT: Gould Electronics Applicability Determination Request for 40 CFR part 63, Subpart N: Chromium Electroplating and Anodizing NESHAP

FROM: John B. Rasnic, Director

Manufacturing, Energy and Transportation Division

Office of Compliance

TO: David Kee, Director

Air and Radiation Division

Region 5

In correspondence with Region 5, Gould Electronics asks for a determination as to whether the plating process used at their McConnellsville, Ohio, facility must comply with the Chromium Electroplating and Anodizing NESHAP. In reviewing the information supplied to this office, this facilitys plating process falls outside the scope of the regulation in question. An explanation follows.

Gould Electronics employs a conversion coating process to plate a thin layer (0.005 to 0.01 micron) of chrome (III) on to a copper substrate. The finished product is used in the manufacture of printed wiring boards. The plating solution contains less than 2.0 grams per liter of chromic acid (CrO3). The residence time in the bath is limited to four (4) to six (6) seconds. A small electrical current (< 30 amp/ft2)is used to accelerate the deposition. These values and the properties expected from the coating do not indicate either hard nor decorative electroplating. Because an electrical current is employed, the possibility exists of chromium mist being emitted above the permissible limits. The region or state may request emissions data to determine whether any chromium mist is produced during operation of this bath.

Please direct any questions to Greg Waldrip of my staff at 202-564-7024.