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May 30, 1998

Mr. Tim Bricker
Engineering Coatings
P.O. Box 306
Bryan, Ohio 43506

Dear Mr. Bricker:

I am writing in response to your request to the U.S. Environmental Protection Agency (EPA), Office of Air Quality Planning And Standards (OAQPS) for an approval of an alternative test method to demonstrate compliance with 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).

In your letters, you stated that the proposed alternative test method would consist of a performance test that would include: 1) a daily leak test of the process system (tank, enclosure, etc.) and 2) a third party OSHA test for measurement of work place chromium emissions surrounding the plating process system. The system leak test would be conducted once per day by using a positive pressure (compressed air or possible left-over chromic acid emissions); but not during the actual plating operation. The annual OSHA test would consist of monitoring for chromium emissions in the surrounding work area for a period of 24 hours while the plating process is in operation.

As you know, your tank emissions are to be controlled by an air pollution control device that is not addressed in the Chrome Plating NESHAP. 40 CFR § 63.343(d) specifies that the owner or operator shall submit, 1) a description of the device, 2) test results collected in accordance with § 63.344(c) verifying the performance of the device for reducing chromium emissions, and 3) a copy of the operation and maintenance plan referenced in § 63.342(f) including the proposed work practice standards, and appropriate operating parameters that will be monitored to establish continuous compliance. 40 CFR § 63.344(c)(4) states that a test method alternative to those listed in § 63.344(c)(1)-(3) may be used if the method has been validated using Method 301, appendix A of subpart N, and if the method has been approved by the Administrator.

To date, we have received general and specific information relating to the design and operation of the plating process system and air pollution control device. We have received limited information regarding the leak testing of the system, the proposed Work Practices, and the planned OSHA monitoring for chrome mist emissions prior to and during the plating operation.

The performance test methods specified in §63.344 are not applicable to your proposed chrome emissions control system; therefore, under §63.344, you, representing the source owner/operator, must validate your proposed method using Method 301 and/or request approval from the Administrator as outline in §63.7(f). Under §63.7(f), you must submit alternative test methods for a.) demonstrating initial compliance of the chrome plating process and associated emission control system and b.) establishing appropriate operating parameters that will be monitored for continuous compliance with the standards . The detailed alternative methods must be reviewed and approved by the Administrator of the U.S. EPA or her designee.

It is our understanding that the emission control system in question has not been constructed and that you are requesting prior approval before undertaking its fabrication. We believe that the proposed alternative test method and emissions control device have some merit and approve their concept based on the information provided to the EPA thus far, however, we cannot approve the alternative test methods for the 1) performance test and 2) the continuous compliance monitoring until the detailed test methods have been reviewed and evaluated along with their test protocol and applicability.

The following is a list of information and/or documents that must be prepared and submitted for review and approval prior to and during operation:

  1. Alternative Test Methods (Method 301 Evaluation Results or Administrator approval).
  2. Initial Notification Report; subject to regulation.
  3. Notification of Construction/Reconstruction.
  4. Initial Performance Demonstration Test Plan; includes detailed test methods and other pertinent data.
  5. Continuous Compliance Monitoring Demonstration Test Plan; includes detailed test methods and other pertinent data.
  6. Operation and Maintenance Plan; includes Work Practices and other pertinent data.
  7. Notification of Performance Test; 60 days advanced noticed required.
  8. Performance Test Results Report & Notification of Compliance Status.
  9. Ongoing Compliance Status Report.

The emission test methods that are normally used to verify the performance of the system are Methods 306, 306A, 306B, CARB Method 425, or an alternate method as validated through the use of Method 301. Continuous compliance with the regulation is usually demonstrated through on-going monitoring of emission data limitations that have been established during the performance test (see §63.343(c)).

 

The performance test shall provide the following data:

  1. verification that there are no chromium leaks in the subject system (includes tank, sealed enclosure, condenser, filters, and connecting hardware) during the plating process.
  2. verification that the enclosure access openings have been sealed and made leakproof after opening and closing.
  3. verification that upon completion of plating operation and dwell time that no chromium emissions escape from the enclosure when access doors are opened to remove parts.
  4. verification of C+6 emissions limitation at the filter/PVC pipe exit during plating operation; 3 test runs required. System exhaust should be tested for C+6 not total chromium.
  5. the average velocity pressure at the outlet of the emission control device (filters); simultaneous during the C+6 performance test to establish continuous compliance operating range. Note: Probably will have to use micro-manometer, transducers or an approved alternative low flow measurement device.

The continuous compliance monitoring test shall include the following:

  1. conduct a daily pressurized leak test on the emission control system (includes tank, sealed enclosure, condenser, filters, and connecting hardware) prior to the plating process operation. More frequent leak check intervals may be required if leaks are routinely found.
  2. conduct and record visual checks for chromium leaks associated with the enclosure access openings. These visual checks shall be conducted and recorded once every 2 hours during the first 40 hours of operation. If no chromium leaks are detected, during the first 40 hours of operation, checks may be conducted once every 4 hours. If chromium leaks are detected during the 4 hour period, corrective action must be performed, and the operator must return to the former condition that checks for leaks once every 2 hours, for a period of 40 hours.
  3. monitor and record the velocity pressure at the outlet of the emission control device (filter) during the plating operation. The operator may set as the compliance value the average velocity pressure measured during the three performance test runs with the tolerance of such measurement being + 10 percent of the measured average value. The velocity pressure shall be monitored and recorded once each day that the affected source is operating.
  4. monitor and record filter solution level (sodium metabisulfite) daily.
  5. conduct OSHA test during plating operation for chromium emissions in work place area surrounding the chrome plating system once every 6 months for the first year. If chromium emissions are determined to be below the permissible exposure limit for first year, OSHA tests may be conducted annually. If the test value is above the permissible exposure limit, perform corrective action and continue to conduct OSHA test once every 6 months for a period of two years.

To assist you in preparing the proposed alternative methods, I have attached several examples with a defined format that should be followed when preparing the methods. I must emphasize that these methods should be prepared in sufficient detailed to identify all equipment, operations, and data collection schedules and procedures.

After you have installed the proposed emission control system, a detailed plan for the performance test and continuous compliance monitoring programs along with a detailed operation and maintenance plan during process operation will have to be prepared and submitted to the U.S. EPA Region 5 office for review and approval. The Chrome Plating NESHAP requires that prior to conducting the performance test, you must notify the EPA authority 60 days in advance of the test date.

Questions regarding this correspondence should be directed to Mr. Clyde E. Riley, U.S.

Environmental Protection Agency, Mail Drop 19, Research Triangle Park, North Carolina 27711, Telephone No. (919) 541-5239.

Sincerely,

 

Clyde E. Riley

Emission Measurement Center

 

Attachments (4)

 

cc: Julie Ackerman, Ohio EPA

Lalit Banker, EPA, OAQPS/ESD (MD-13)

Julie Brandt, EPA, Region V

William Lamason, EPA, OAQPS/EMAD (MD-19)

Phil Mulrine, EPA OAQPS/ESD (MD-13)

Robin Segall, EPA, OAQPS/EMAD (MD-19)

Scott Throwe, EPA, OECA



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