MEMORANDUM

(recd 9-16-97)

SUBJECT: Compliance Status Reports for the Chromium Electroplating MACT

FROM: John B. Rasnic, Director, Manufacturing, Energy and Transportation Division Office of Compliance

TO: Regional Chrome Electroplating MACT Contacts

The purpose of this memorandum is to clarify when the initial compliance status reports are due for the National Emission Standard for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks.

Section 63.347(g) requires the owner or operator of an affected facility located at a major site to submit a summary report to the Administrator to document the ongoing compliance status of the affected source. Section 63.347(h) requires owners and operators of area sources to prepare a similar compliance status report on an annual basis and maintain the information on site to be made available to the Administrator upon request. Much of the information contained in these reports, such as operating parameter values, is established during the initial performance test, which was scheduled to be conducted by July 25, 1997. Owners and operators of affected facilities have conducted their initial performance tests at different times since the January 25, 1997, compliance date. Consequently, there has been some confusion regarding when the initial compliance status reports are due. After discussing this issue with the regional Chrome Electroplating and Air Toxics contacts, we believe that a specific date should be selected for receiving the semiannual report and for availability of the annual report. By selecting a specific reporting date we hope to avoid the confusion of site specific reporting periods. We believe the appropriate reporting dates are as follows:

For major sources:

The initial compliance status report should include information from the time period of January 25, 1997, to December 31, 1997, and should be submitted within 30 days after December 31, 1997. For those sources that conducted their initial performance test prior to the July 25, 1997, deadline, this initial report will include more than six months of compliance information. Subsequent semiannual reports will be due July 30 and January 30 and will include the previous six months of compliance information specified in §63.347(g)(3).

For area sources:

The initial compliance status reports should include information from the time period of January 25, 1997, to December 31, 1997, and should be available on site within 30 days after December 31, 1997. Since many sources did not conduct their initial performance tests until July 1997, these initial compliance status reports may include less than one year of compliance information. However, as we stated above, we selected a specific date to provide consistency in reporting periods. Subsequent annual reports must be available within 30 days of the end of each calendar year and will include the compliance information in §63.347(g)(3).

If you have any questions regarding this memorandum, please contact Scott Throwe of my staff at (202) 564-7013.