3/1/95

Bruce L. Piccirillo

LTV Steel Company

3001 Dickey Road

East Chicago, Indiana 46312

Re Applicability Determination Request for Chromium Electroplating Standard

Dear Mr. Piccirillo:

On January 25, 1995, the United States Environmental Protection Agency (U.S. EPA) set National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 C.F.R. Part 63, Subpart N). Your July 21, 1995, and August 21, 1995, letters ask whether this standard applies to the continuous chromium electroplating of steel at LTV Steels East Chicago facility.

Within the U.S. EPA, the Region 5 Office, the Office of Air Quality Planning and Standards (OAQPS), the Office of Enforcement and Compliance Assurance, and the Office of General Counsel reviewed your request. These Offices concluded that the U.S. EPA clearly intended to regulate all sources that perform chromium electroplating. The U.S. EPA noted that the operating parameters for the electroplating and chemical treatment processes at LTV all fall within ranges of the hard and decorative parameters in the current NESHAP, and there is data indicating that control technology is available and feasible. However, the U.S. EPA also concluded that continuous chromium electroplating of steel is uniquely different from the hard and decorative chromium electroplating categories specified in the existing standard. Thus, the U.S. EPA plans to amend the standard to explicitly include continuous chromium electroplating of steel.

The OAQPS has agreed to take the lead in completing the regulatory changes. Depending on the approach that OAQPS selects and the available resources, it should take 6 to 12 months to amend the standard to appropriately cover operations that continuously electroplate steel with chromium.

While this activity is proceeding, Region 5 urges LTV Steel to begin work on controlling chromium emissions from its East Chicago facility. This includes, but is not limited to, investigating control options, budgeting for control devices, and maintaining open and clear communications with U.S.EPA regarding such control measures. By taking such steps, LTV Steel will reduce chromium emissions as early as possible. Hexavalent chromium is a highly toxic air pollutant. I encourage LTV Steel to take this approach in the spirit of public health protection.

If my staff can be of assistance in your efforts, or in establishing a dialogue with OAQPS, please let us know. If you have any questions on this matter, please contact Cynthia (Cyd) Curtis, of my staff, at (312) 353-6959.

Sincerely,

George T. Czerniak, Chief

Air Enforcement and Compliance Assurance Branch

cc: Felicia George, Assistant Commissioner

Office of Air Management

Indiana Department of Environmental Management