May 20, 1996
Kevin A. Doyle
National Steel Corporation
Midwest Division
U.S. Route 12
Portage, Indiana 46368
Re: Applicability Determination Request for
Chromium Electroplating Standard
Dear Mr. Doyle:
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
July 21, 1995, letter asks whether this standard applies to the
continuous chromium electroplating of steel at National Steel
Coporations Midwest Steel facility (Midwest Steel).
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 Agency noted that most of the operating parameters for the
Weirchrome line at Midwest Steel fall within the range of hard
and decorative parameters in the current NESHAP, and 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 National Steel
Coporation to begin work on controlling chromium emissions from
its Midwest Steel 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, National Steel Corporation
will reduce chromium emissions as early as possible. Hexavalent
chromium is a highly toxic air pollutant. I encourage National
Steel Corporation to take this approach in the spirit of public
health protection.
If my 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