Presented in Partnership with:

Mr. Lawrence E. Tock

Corporate Environmental Engineer

Techneglas, Inc.

727 E. Jenkins Avenue

Columbus, Ohio 43207

Dear Mr. Tock:

We are writing in response to your request for approval of an alternative compliance test method proposed by Techneglas, Inc. for performance testing/demonstrating compliance of the emission elimination device (EED) manufactured by Responsible Alternatives already installed on one of the two hard chromium electroplating tanks at the Techneglas facility in Columbus, Ohio and a second EED to be installed on the second hard chromium electroplating tank in the near future. We understand from the letter sent to you on October 21, 1999 from Yasmine Wadia of the U. S. Environmental Protection Agency (EPA) Region 5, that both tanks are subject to the National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks ("Chrome Plating NESHAP") (40 CFR Part 63, subpart N.) The performance test methods specified in §63.344 are not applicable to these EEDs; therefore, an alternative method for demonstrating compliance of the control device must be proposed by the source owner/operator and approved by the Administrator of the EPA or her designee.

We have received and reviewed the information that you submitted to Ms. Yasmine Wadia of EPA Region 5 on September 30, 1999 in which Techneglas has proposed an alternative test method for the EED. The alternative test method proposed utilizes a smoke generation device. This device is ignited and placed inside the EED to confirm integrity of the EED seals, joints, and membranes and to demonstrate proper installation of the EED so as to completely enclose the atmosphere over the chrome electroplating tank, with the exception of (1) the gases (e.g., hydrogen and oxygen) which exit the semi-permeable membranes of the EED during the plating operation and (2) the evacuation and filtering of any mists or fumes remaining under the EED prior to opening the EED at completion of a plating run.

Based on prior observation of the proposed alternative method by Mr. Greg Waldrip of the EPA’s Office of Enforcement and Compliance Assurance, we are approving the proposed alternative test procedure as transcribed in the enclosure to this letter to demonstrate performance and compliance of the EED as applied to the hard chromium electroplating tanks at the Techneglas facility; note requirement to heat the plating bath in the tank to be tested to normal operating temperature. Recognizing the qualitative nature of this performance test method, leaks observed in the EED during conduct of this approved testing procedure shall be considered as indications of noncompliance with the Chrome Plating NESHAP.

Please be aware that this letter only constitutes approval of an alternative performance test method for application to the EED’s at Techneglas, Inc.; you should continue to work with EPA Region 5 for approval of an alternative monitoring method under §63.343(c)(8).

You may contact Robin Segall, of the Emission Measurement Center staff at (919) 541-0893, if you have any questions regarding this letter or need additional information.




J. David Mobley, Acting Director

Emissions, Monitoring, and

Analysis Division


cc: Acting Director, Air and Radiation Division, Region V

Yasmine Wadia, EPA Region V

Mike Riggleman, Ohio EPA

Scott Throwe, EPA/OECA

Lalit Banker, EPA/OAQPS/ESD

Phil Mulrine, EPA/OAQPS/ESD

Robin Segall, EPA/OAQPS/EMAD






1. Applicability and Principle

1.1 Applicability. If approved on a site-specific basis, this alternative method is applicable to hard chromium electroplating and anodizing operations where an Emission Elimination Device©(EED) is used on the tank for reducing chromium emissions.

1.2 Principle. During chromium electroplating or anodizing operations, bubbles of hydrogen and oxygen gas generated during the process rise to the surface of the tank liquid and burst. Upon bursting, tiny droplets of chromic acid (chromium mist) become entrained in the air above the tank. Because the EED completely encloses the air above the tank, the chromium mist either falls back into the solution because of gravity or collects on the inside walls of the EED and runs back into the solution. A semi-permeable membrane allows passage of the hydrogen and oxygen out of the EED. A smoke device is placed inside the EED and lit to detect leaks at the membranes, joints, or seals.

2. Apparatus

2.1 Smoke device. Adequate to generate 500 to 1000 ft3 of smoke/20 ft2 of tank surface area (e.g., Model #1A=15 SECONDS from Superior Signal, New York).

2.2 Small metallic container. To hold the smoke device.

3. Procedure

Heat the plating bath in the tank to be tested to normal operating temperature. Place the small container on a stable and flat area at center of the EED covering the tank (use a piece of material to span the buss bars). Place the smoke device inside the container. After lighting the smoke device, quickly close the lid and seal the door to prevent smoke from escaping the EED. Let the smoke device completely burn; the entire space under the EED will now be filled with the smoke. Observe for leaks of smoke from each seal, joint, and membrane of the EED. Record these observations including the locations and a qualitative assessment of any leaks of smoke.

After all seals, joints, and membranes have been observed, turn on the evacuation unit to remove the smoke from the EED.




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