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4/16/96

Scott F. Wilson, P.E.

Moyno Industrial Products

P.O. Box 960

Springfield, Ohio 45501-0960

Re: Chromium MACT Compliance Extension Moyno Industrial Products, Springfield, Ohio

Dear Mr. Wilson:

This letter is in response to your March 14, 1996, letter requesting a one year extension of the compliance deadline in the National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (Chrome Plating NESHAP) for the hard chromium electroplating tanks at Moyno Industrial Products (Moyno).

As explained in the April 10, 1996, telephone conversation with Sarah Miller, of my staff, your March 14, 1996, letter does not provide enough information to grant your request. In accordance with the General Provisions, 40 C.F.R. § 63.6(i)(6)(i) you need to provide:

(A) A description of the controls to be installed to comply with the standard;

(B) A compliance schedule, including the date by which each step toward compliance will be reached. At a minimum, the list of dates shall include:

(1) The date by which contracts for emission control systems or process changes for emission control will be awarded, or the date by which orders will be issued for the purchase of component parts to accomplish emission control or process changes;

(2) The date by which on-site construction, installation of emission control equipment, or a process change is to be initiated;

(3) The date by which on-site construction, installation of emission control equipment, or a process change is to be completed; and

(4) The date by which final compliance is to be achieved;

(C) A description of interim emission control steps that will be taken during the extension period, including milestones to assure proper operation and maintenance of emission control and process equipment

The information that you provide should clearly identify the affected tanks. I understand that your tank emissions are currently controlled with a packed bed scrubber. In your return correspondence please include the scheduled performance test date(s) and clarify that the compliance extension will not be required in the event of testing results within the 0.015 mg Cr/dscm limit of the Chrome Plating NESHAP.

As discussed on the telephone with Sarah Miller, the compliance date marks the date on which controls capable of meeting the standard must be installed and in operation. Additionally, the operation and maintenance plan must be implemented. The initial performance test shall be conducted no later than 180 days after the compliance date. Monitoring to demonstrate continuous compliance (i.e. monitoring and recording the pressure drop across a composite mesh-pad system) begins on the day of performance testing. The Chrome Plating NESHAP states that the performance test deadline for hard chromium electroplating tanks is July 24, 1997. However, in the event that a compliance extension is granted for your facility, we will also grant an extension of the performance testing date to 180 days after the extended compliance date.

You will need to submit the information requested above before July 25, 1996 (six months before the compliance date). We will notify you in writing of approval or intention to deny approval of a compliance extension within 30 calendar days of receipt of the above information.

If you have any questions please contact Sarah Miller at (312) 886-6088.

Sincerely yours,

George Czerniak, Chief

Enforcement Branch

Air and Radiation Division

cc: Sherri Swihart, OEPA

Andy Roth, RAPCA

Greg Waldrip, OECA



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