Presented in Partnership with:


James Ruddock

Environmental Coordinator

Hastings Manufacturing Company

325 North Hanover Street

Hastings, Michigan 49058-1598

Re: Chromium Electroplating Emission Standard Compliance Extension Request

Dear Mr. Ruddock:

On January 15, 1996, Hastings Manufacturing Company (Hastings) sent a Compliance Extension Request to the United States Environmental Protection Agency (U.S. EPA), Region 5. Also, on March 18, 1996, Hastings submitted additional information toU.S. EPA to supplement the initial request. Hastings owns and operates four chromium electroplating tanks that are subject to the National Emission Standards for Chromium Emissions From Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (Chrome Plating NESHAP). Hastings operates hard chromium electroplating tanks that plate cast iron and steel piston rings. The compliance provisions of this standard, 40 CFR Section 63.343, require that hard chromium electroplating tanks comply no later than January 25, 1997.

The compliance provisions of the Chrome Plating NESHAP also allow a source up to one additional year to comply with the standard. Under this provision, Hastings has requested a compliance extension of 1 year for the four chromium electroplating tanks at the Hastings, Michigan facility. Currently, Hastings has two packed bed scrubbers/composite mesh pad systems and two packed bed scrubbers/chevron blade systems to control chromium emissions. Hastings has requested a compliance extension to replace the existing pollution control devices that will enable Hastings to comply with the Chrome Plating NESHAP.

In November 1995, Hastings chose an engineering firm, through a bid process, to design, specify and install the emission control equipment. However, the efforts were curtailed due to the financial strength of Hastings. As a result, Hastings has requested a compliance extension for approximately 1 year until adequate funding is available to install the emission control equipment necessary to comply with the Chrome Plating NESHAP.

In the submittal dated March 18, 1996, Hastings outlined a schedule for achieving compliance with the Chrome Plating NESHAP. The steps outlined and the expected completion dates are as follows:

Award "Phase I" Engineering Contract May 1, 1997

Award emission control system and/or process change contracts June 15, 1997

On-Site construction, installation of emission control equipment and/or process change initiated August 15, 1997

On-site construction, installation of emission control equipment and/or process change completed October 1, 1997

Troubleshooting, operation and Final compliance January 1, 1998

On August 7, 1995, the U.S. EPA Administrator delegated the authority to grant compliance extensions to the Regions. Under this authority, Region 5 extends the compliance date for Hastings to January 1, 1998. As a condition of this compliance extension, in accordance with 40 CFR Section 63.6(i)(11), Hastings shall submit monthly progress reports on the installation of the pollution control devices beginning in June 1997. These progress reports shall be submitted, by the last day of each month, to: U.S. EPA, Region 5, Air Enforcement and Compliance Assurance Branch, 77 West Jackson Boulevard, Chicago, Illinois 60604, with a copy to Diane Kavanaugh, Air Quality Division, Michigan Department of Environmental Quality, Hollister Building, 106 West Allegan Street, P.O. Box 30260, Lansing, Michigan 48909. In conjunction with this compliance extension, the performance test required under 40 CFR Section 63.344 of the Chrome Plating NESHAP must be performed within 180 days after the termination of the compliance extension pursuant to 40 CFR Section 63.7(a)(1)(v).

If you have any questions related to this compliance extension, please contact Karen L. Bell, of my staff, at (312) 353-8640.

Sincerely yours,

George T. Czerniak, Chief

Air Enforcement and Compliance Assurance Branch

cc: Diane Kavanaugh

Michigan Department of Environmental Quality


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