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[The following is a letter written by Mr. Frank Clay (retired EPA and inventor of Method 306A protocol for chromium emissions testing) to Ms. Carol Browner (EPA Administrator). Topics include: A) The applicability of the Chromium NESHAPs mandatory stack test to a hard chrome plating tank that uses only fume suppressants and has no vent system or stack to test; and B) Benefits of stack test Method 306A.]

1714 Park Drive Raleigh, North Carolina 27605-1611

12 January 1998

Ms. Carol Browner
United States Environmental Protection Agency
MC 1101
401 M Street, South West
Washington, D.C. 20460

Dear Ms. Browner:

In the December 1997 issue of Plating and Surface Finishing (PASF), I saw that you are planning to address the AESF/EPA Conference in Florida this coming January 26 - 30. I have enclosed some information that I hope you may find useful for the conference. It concerns the Common Sense Initiative (CSI) program, and also Method 306-A, which I believe is a good example of how the Agency is working to help the plating industry.

Prior to my retirement from the U.S. EPA in July 1996, I worked on the Chromium NESHAP, gathering test data and writing sampling methods. During this past year, I performed some compliance sampling for the plating industry, and many of the platers spoke favorably of the CSI.

From the conference presentation schedule in the December issue of PASF I noticed that David Ferguson of the U.S. EPA in Cincinnati, Ohio is making a CSI presentation on the use of wetting agent fume suppressants in hard chromium tanks. This past summer, I tested some facilities that used this technology and the emissions were substantially less than the allowed standard. One case in particular is interesting, and was a facility that the EPA tested in 1986. At the time, it was the most efficient control device that we had seen, but it still would not pass the present concentration standard. Although the original control device was retained, the use of a fume suppressant allowed the facility to satisfy the requirements for compliance. While fume suppressants lower mist emissions and facilitate meeting compliance requirements, there are some hard platers who are using fume suppressants as their primary means of control and have no ventilation system. This makes showing compliance difficult since this plating configuration is not covered in the NESHAP: it may be worthy of future consideration.

The CSI program has produced many benefits for the plating industry. Perhaps another benefit to the industry is Method 306-A which incorporates some of the cleaner, cheaper, smarter concepts of the CSI. A thorough explanation of the method can be found in an article by Frank Altmayer which is enclosed.

Ms. Carol Browner Page 2 12 January 1998

The benefits to the plating industry from Method 306-A are many. The method is a more simple way to show compliance than traditional isokinetic sampling. Platers are able to construct their own sampling apparatus and perform their own testing which meant that some small platers were able to keep their businesses. If the platers chose to use consultants to perform the testing, the simplified method is cheaper. The method also enables the manufacturers of control equipment to perform compliance tests on that equipment shortly after it is installed. The availability of an alternate method (306-A versus 306) resulted in consultants charging fair prices for compliance testing rather than what the market would bear. Many of them used Method 306-A. Because of Method 306-A, showing compliance was easier and less costly for the industry.

I hope that the information on the CSI and Method 306-A is useful to you and that your experience at the conference is a pleasant one.


Frank R. Clay


[The following is EPAs response to Frank Clays 1/12/98 letter to EPAs Administrator. The reply came from Henry Thomas, for Director John Seitz (Office of Air Quality and Standards), rather than from Ms. Browner herself. Topics include: A) The applicability of the Chromium NESHAPs mandatory stack test to a hard chrome plating tank that uses only fume suppressants and has no vent system or stack to test; and B) Benefits of stack test Method 306A.]

Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711

FEB 2 0 1998
Mr. Frank Clay
1714 Park Drive
Raleigh, North Carolina 27605

Dear Mr. Clay:

This is in response to your letter of January 12, 1998, to the Administrator, Ms. Carol Browner, suggesting that the Environmental Protection Agency (EPA) reconsider source testing requirements for some hard chrome platers that use fume suppressants to control chromium emissions to comply with the applicable rule. The rule requires all hard chrome platers, irrespective of their size or the control technology used, to perform a source test to show compliance with the rule. The source has to perform this test according to method 306 or 306A as described in the rule with the measurement conducted through the stack. As you pointed out that there are certain instances where the source using the fume suppressants as the control technology may not have any ventilation through a stack, which makes it difficult to perform a stack test.

While there have been some instances where the sources have installed temporary hoods or ductwork to perform the required source test, Mr. Daniel A. Cunningham of the Metal Finishing Association of Southern California wrote to us with a request similar to yours. He, along with the South Coast Air Quality Management District in California, performed source tests at two such hard chrome platers which have fume suppressants as the only control technology to show that these operations can comply with the rule. After evaluating the source test results, we agreed with their suggestions that some very small hard chrome platers using fume suppressants can be granted waivers from the source test requirements if they met the criteria as described in my response letter to their request. I have attached a copy of that letter for your information. If there are sources that meet these criteria, they can approach their respective State EPA or Regional office, where a case-by-case evaluation will be made. We agree with the benefits of the method 306A that you have described in your letter.

I appreciate this opportunity to be of service and trust this information will be helpful to you. If you have any further questions regarding this, please contact Lalit Banker at (919) 541-5420.


Henry Thomas
for John Seitz
Office of Air Ouality Planning and Standards


cc: Lalit Banker, MD-13
Bruce Jordan, MD-13
Conniesue Oldham, MD-19
Robin Segall, MD-19
Susan Wyatt, MD-13


[The following letter from EPA to the Metal Finishing Association of Southern California discusses EPAs willingness to grant source test waivers for some small, existing hard chrome plating facilities that use only fume suppressants to meet chromium emission limits in the MACT Standards.]

JAN 16 1998

Mr. Daniel A. Cunningham, Executive Director
Metal Finishing Association of Southern California
5000, Van Nuys Boulevard, Suite 305
Sherman Oaks. California 91403

Dear Mr. Cunningham:

This is in response to your July 31, 1997, request to allow very small hard chrome platers using fume suppressants for chromium emissions control to demonstrate compliance through surface tension measurements rather than emission testing. Your purpose is to avoid significant expenses that may occur for these sources to construct or modify hood and ventilation systems to allow proper testing to be conducted. In July you provided source test data on the fume suppressant control efficiency and emission rate from one facility. Based on our request for additional information, you provided data from subsequent tests conducted in November at two facilities. We have now completed review of all the test data you submitted.

Based on this review, we have determined that limiting the surface tension at certain existing small hard chrome platers will achieve equivalent emission reduction and ensure compliance with the emission limits in our national emission standard. This finding is applicable to other States as well as California. Based on the review of the data provided, we agree with your suggested criteria for a source to be accepted into this category. Thus, we have established the following conditions which must be met for a hard chrome plating operation to be considered for a source test waiver:

  1. The operation must be an existing source (constructed prior to 1993).
  2. A mist suppressant must be used in the tank to control chromium emissions and the surface tension must not exceed 45 dynes/centimeter.
  3. The facility must not use more than 500,000 ampere-hours per year. This will be verified through the installation of a hard-wired non-resettable ampere-hour meter and a requirement to maintain daily record of usage

In addition, the operator will have to follow applicable on-going monitoring and recordkeeping/reporting requirements for surface tension measurements which are the same as those required of the decorative chrome platers using fume suppressants control technology. The source could operate with or without polyballs since the source test results demonstrated compliance either way. However, the State or local agency could require the use of the polyballs along with the mist suppressant. The operator will have to submit to the applicable EPA regional office a plan describing the alternative control technology (fume suppressants instead of an add-on control) and monitoring to be used, and a request to waive the performance test requirement. The regional offices will have the authority for performing case-by-case evaluations to determine whether these waivers can be granted. They will evaluate each case based on the criteria and conditions described above.

I appreciate this opportunity to be of service and trust this information will be helpful to you. If you have any further questions regarding this, please contact Lalit Banker at (919) 541-5420.

John S. Seitz (/s/ Henry Thomas)
Office of Air Quality Planning and Standards

cc: Kingsley Adeduro, Region IX
Mohan Balagopalan, SCAQMD
Lalit Banker, MD-13
Ken Bigos, Region IX
Fred Dimmick, MD-13
Charlie Garlow, OECA
Dean High, PES
Phil Mulrine, MD-13
Robin Segall, MD-19
Scott Throwe, OECA
Al Vervaert, MD-13
Mark Watkins, CARB
Susan Wyatt, MD-13
Air Directors, Regions I-X


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