1/9/96

Mr. Vinod V. Patel

Techmetals, Incorporated

Post Office Box 1266

Dayton, Ohio 45401-1266

Dear Mr. Patel:

I am writing in response to our telephone conversations and the forwarding of a letter you sent to Lalit Banker of the Emission Standards Division of the United States Environmental Agency ("U.S. EPA"), dated September 18, 1995, to this office. I hope to both further clarify the relationship between your tank and the National Emission Standards from Chromium Emissions From Hard and Decorative Chromium Electroplating and Anodizing Tanks (40 CFR part 63, subpart N) ("Chrome Plating NESHAP") and detail the steps that you should take in order to use the Merlin control device to comply with the Chrome Plating NESHAP.

You state in your September 18, 1995, letter, that you operate a hard chromium plating tank equipped with a Merlin control device. As explained in the November 13, 1995, response letter from Susan Wyatt of the Emissions Standards Division of U.S. EPA, your tank is not exempt from the Chrome Plating NESHAP due to your use of a Merlin control device. Your tank remains subject because it is used to perform hard chromium electroplating. The compliance date for hard chromium electroplating tanks is January 25, 1997. Since you have selected a type of control for this tank that is not discussed in the Chrome Plating NESHAP (and will therefore need to use an "alternative monitoring method"), you must comply with section 63.343(d) of this regulation, which states,

An owner or operator who uses an air pollution control device not listed in this section shall submit a description of the device, test results collected in accordance with section 63.344(c) verifying the performance of the device for reducing chromium emissions to the atmosphere to the level required by this subpart, a copy of the operation and maintenance plan referenced in section 63.342(f) including proposed work practice standards, and appropriate operating parameters that will be monitored to establish continuous compliance with the standards. The monitoring plan submitted identifying the continuous compliance monitoring is subject to the Administrators approval.

You should submit the information outlined above to my attention at the Region 5 Office of the U.S. EPA. This submission should be made as soon as possible to facilitate a thorough review, but must be made at least 60 days before the completion date of performance testing, which is July 24, 1997, for your hard chromium electroplating tank. The description of the Merlin control device that you have already submitted is on file, and only needs to be supplemented with specific information about the Merlin device(s) in place at your facility. As explained above, you should also send the test results, operation and maintenance plan, and alternative monitoring parameters.

I recommend that you begin preparing this submission as soon as possible. This is especially important because the material you have provided so far suggests that an alternative test method is needed to collect air emissions data. Under 40 CFR § 63.344(c)(4) an alternative test method can be used if it has been validated using Method 301 in Appendix A of 40 CFR Part 63, and the alternative is approved by the Administrator. This approval has been delegated to the Director of the Office of Air Quality Planning and Standards ("OAQPS") and the procedures for requesting and obtaining approval are contained in 40 CFR § 63.7(f). The contact at OAQPS on this matter is Robin Segall and her phone number is (919) 541-0893. Written material should be sent to her attention at Mail Drop 19, U.S. EPA, Research Triangle Park, NC 27711. As a time saving measure, please copy me on information sent to OAQPS as well as keeping the Regional Air Pollution Control Agency in Dayton, Ohio, aware of your actions.

I suggest that you work with Merlin Enterprises to develop and obtain approval for this alternative test method. Please be aware that it may take several months for the alternative to be approved, but the more documentation that you can provide to support your case, the faster the approval process will proceed. This approval is necessary before the method can be used to collect data needed for the submission of the alternative monitoring method and the performance test.

I recognize that the Merlin control is a rather unique control device and that the development of an alternative test method and monitoring parameters may not be straightforward. I hope that the above requirements will not be overly burdensome and that Techmetals, Merlin Enterprises, and U.S. EPA in conjunction with Ohio EPA, can work together to reach a solution. The requirements are necessary to insure that your hard chromium electroplating tank continuously meets the emission limits in the Chrome Plating NESHAP.

I apologize that this letter has been delayed due to the Federal government shutdowns and the furlough of employees. Please contact me at (312) 886-6088 if you have questions or need additional assistance.

Sincerely,

Sarah Miller, Environmental Scientist

Air Enforcement and Compliance Assurance Section (MN/OH)

cc: Peter Westlin, OAQPS

Robin Segall, OAQPS

Lalit Banker, OAQPS

Greg Waldrip, OECA

Sherri Swihart, Ohio EPA

Andy Roth, RAPCA