May 20, 1996

Charles G. Carson, III

Vice President

Environmental Affairs

U.S. Steel

600 Grant Street

Pittsburgh, Pennsylvania 15219-2749

Re: Applicability Determination Request Chromium Electroplating Standard for U.S. Steels Gary, Indiana facility

Dear Mr. Carson:

On January 25, 1995, the United States Environmental Protection Agency (U.S. EPA) set National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (40 C.F.R. Part 63, Subpart N). Your October 16, 1995, letter asks whether this standard applies to the continuous chromium electroplating of steel at U.S. Steels Gary, Indiana and Fairless, Pennsylvania facilities. This response from Region 5 concerns U.S. Steels Gary facility. You should receive a separate response from Region 3 for the Fairless facility.

Within the U.S. EPA, the Region 5 Office, the Office of Air Quality Planning and Standards (OAQPS), the Office of Enforcement and Compliance Assurance, and the Office of General Counsel reviewed your request. These Offices concluded that the U.S. EPA clearly intended to regulate all sources that perform chromium electroplating. The U.S. EPA noted that: your facilitys tin free steel process line clearly performs chrome electroplating; the electrolytic tin lines, wherein electrical charge is applied to the baths, may also be considered chrome electroplating; and that there is data indicating that control technology is available and feasible. However, the U.S. EPA also concluded that continuous chromium electroplating of steel is uniquely different from the hard and decorative chromium electroplating categories specified in the existing standard. Thus, the U.S. EPA plans to amend the standard to explicitly include continuous chromium electroplating of steel.

The OAQPS has agreed to take the lead in completing the regulatory changes. Depending on the approach that OAQPS selects and the available resources, it should take 6 to 12 months to amend the standard to appropriately cover operations that continuously electroplate steel with chromium.

While this activity is proceeding, Region 5 urges U.S. Steel to begin work on controlling chromium emissions from its Gary facility. This includes, but is not limited to, investigating control options, budgeting for control devices, and maintaining open and clear communications with U.S. EPA regarding such control measures. By taking such steps, U.S. Steel will reduce its chromium emissions as early as possible. Hexavalent chromium is a highly toxic air pollutant, and I encourage U.S. Steel to take this approach in the spirit of public health protection.

If Region 5 staff can be of assistance in your efforts, or in establishing a dialogue with OAQPS, please let us know. If you have any questions on this matter, please contact

Cynthia (Cyd) Curtis, of my staff, at (312) 353-6959.

Sincerely,

George T. Czerniak, Chief

Air Enforcement and Compliance Assurance Branch

cc: Felicia George, Assistant Commissioner

Office of Air Management