3/1/96

Mr. Dan Grieszmer

Hadronics, Incorporated

4570 Steel Place

Cincinnati, Ohio 45209

Dear Mr. Grieszmer:

I am writing to approve the compliance monitoring and work practice standards proposed by Hadronics for the Number 6 hard chromium electroplating tank. This tank is 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). Because this tank uses an air pollution control device not discussed in the Chrome Plating NESHAP, § 63.343(d) requires that the owner or operator must submit a description of the control device, test results, a copy of the operation and maintenance plan, and the operating parameters that will be monitored to show continuous compliance with the standards. The compliance monitoring and work practice standards must be approved by the Administrator as stated in § 63.342(f)(3)(C) and § 63.343(d).

Hamilton County Environmental Services forwarded your letters to the United States Environmental Protection Agency (U.S. EPA) on January 26, 1996 and February 14, 1996. These letters detail the scheduled performance test for the Number 6 hard chromium electroplating tank at the Hadronics facility, the control devices present on this tank, the operation and maintenance plan (including work practice standards), and the compliance monitoring methods. Following a telephone conversation on February 29, 1996, with Sarah Miller, of my staff, you submitted a revision to the work practice standards. Your submittal increased the frequency of the wash down schedule on the packed bed mist eliminator from once per quarter to once monthly and included a yearly removal and cleaning of the packed bed media. This revision was submitted by facsimile on March 1, 1996, and replaces that section of the operation and maintenance plan.

The U.S. EPA approves the work practice standards proposed by Hadronics in the operation and maintenance plan submitted on February 14, 1996 for the tank, polypropylene balls, primary mist eliminator, ductwork, manometer/Magnehelic gauge, and fan, and the work practice standards for the packed bed mist eliminator as revised in the March 1, 1996, submission. Additionally, U.S. EPA approves the compliance monitoring standards submitted on February 14, 1996. As stated, Hadronics must check daily that the polypropylene balls cover a minimum of 75% of the tank. Additionally, the pressure drop across the primary mist eliminator and packed bed mist eliminator must be checked and recorded on a daily basis. Mirroring the policy for the control devices discussed in the Chrome Plating NESHAP, you may conduct multiple performance tests to establish a range of compliant pressure drop values, or you may set as the complaint value the average pressure drop measured over the three test runs of one performance test and accept +1 inch water column from this value as the compliant range.

While approving the work practice and compliance monitoring standards submitted by Hadronics, U.S. EPA does recommend that Hadronics modify the operation and maintenance plan before the compliance date. The current plan does not adequately address procedures for identifying and correcting equipment and process malfunctions as required by § 63.342(f)(3). The results from stack testing and the revised operation and maintenance plan should be submitted to U.S. EPA. These submissions will complete the requirement of § 63.343(d).

The U.S. EPA does not object to performance testing of the Number 6 tank on the proposed date of March 27, 1996, assuming that Hamilton County Environmental Services agrees. Both agencies should be notified of the finalized testing date. If the performance testing at the Number 6 tank at Hadronics does not meet the limit in the Chrome Plating NESHAP, U.S. EPA recommends that another control device, such as a composite mesh-pad system or a packed bed scrubber, replace the current controls. If the current controls are replaced, the work practice and continuous monitoring standards approved here will no longer apply.

Thank you for your submission. Please keep this letter with your operation and maintenance plan and contact Sarah Miller at (312) 886-6088 if you have any questions or need additional information.

Sincerely,

Valdas V. Adamkus

Regional Administrator

cc: Lee Gruber

Hamilton County Environmental Services

1632 Central Parkway

Cincinnati, Ohio 45210

Wendell Turner

Hixson

659 Van Meter Street

Cincinnati, Ohio 45202

Sherri Swihart, Ohio EPA

Al Vervaert, OAQPS

Robin Segall, OAQPS

Greg Waldrip, OECA