1/11/96

Lawrence W. Mitchell

Gould Electronics, Inc.

35129 Curtis Boulevard

Eastlake, Ohio 44095-4001

Dear Mr. Mitchell:

This is in response to your October 16, 1995, request for applicability determination of the National Emission Standards for Chromium Emissions From Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks ("Chrome Plating NESHAP") (60 FR 4948, January 25, 1995) regarding four tanks (the "JTC" tanks) at the McConnelsville facility of Gould Electronics, Inc. The information in your October 16, 1995, letter was supplemented by a follow-up telephone conversation on December 6, 1995, and a voice mail message on December 8, 1995.

As stated in the letter and telephone conversation, the "JTC" tanks are used for a conversion coating, or chromating, process in which a small electrical current is used to accelerate the deposition of the chromium coating. This chromating process plates a thin layer of chrome (III) onto an electronic grade copper foil to provide protection during shipment and storage before use. The finished product is used in the manufacture of printed wiring boards.

On the basis of the information provided by Gould Electronics, the United States Environmental Protection Agency (U.S. EPA) has concluded that the "JTC" tanks are not subject to the Chrome Plating NESHAP. The concentration of chromic acid utilized in the "JTC" tanks are far below the concentrations of 30 to 50 ounces per gallon traditionally used in decorative or hard chromium electroplating. Similarly, the current density employed in the "JTC" tanks is well below the density range typically used in chromium electroplating. These process parameters suggest that only very low levels of chromic acid mist are produced in the chromating process.

Please understand that this determination was based upon the solution concentration and process parameters provided by Gould Electronics. Any changes in the plating characteristics or bath operating parameters could render the tanks subject to the Chrome Plating NESHAP and would require reevaluation by U.S. EPA. Please contact Sarah Miller at (312) 886-6088 if you have questions or need additional assistance.

Sincerely,

Valdas V. Adamkus

Regional Administrator

cc: Greg Waldrip, OECA

Sherri Swihart, Ohio EPA