MEMORANDUM

SUBJECT: Issues Regarding Shutdown Units Under the Chromium Electroplating MACT Standard

FROM: John B. Rasnic, Director

Manufacturing, Energy and Transportation Division

Office of Compliance

TO: Susan Studlien, Deputy Director.

Office of Ecosystems Protection

Region I

 

This memorandum is in response to your staffs May 15, 1997, memorandum to

Scott Throwe of my staff regarding shutdown units under the National Emission Standard for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (Chromium Electroplating MACT Standard)

You provided the following background and questions:

Background

A facility owns a hard chromium tank which is currently filled with water and not operated. The tank has not been operated for over a year and it is not anticipated to be operated prior to July 25, 1997, the date by which compliance testing for an affected source under the MACT Standard is required to be completed. The consultant estimates that when the source does start to operate again, startup costs will be minimal. This situation results in the following questions.

1) Is the source described an affected source under the Chromium Electroplating MACT Standard?

2) When is the source required to install controls?

3) When is the source required to conduct its performance test?

4) What emission limit is the source subject to when it recommences operation?

5) If the source is a hard chrome tank, when must it have federally-enforceable restrictions in place to classify itself as a small chrome plater?

6) What are the initial notification requirements?

The following are our responses to your questions:

1) Is the source described an affected source under the Chromium Electroplating MACT Standard?

The affected source is each chromium electroplating or anodizing tank at facilities performing electroplating or anodizing. Chromium electroplating or anodizing tank is defined as the receptacle or container in which hard or decorative chromium electroplating or chromium anodizing occurs. Because the tank in question is shutdown and electroplating is not currently occurring, the source is not an affected source. This determination applies to tanks which are shutdown and are not in operational condition, it is not intended to apply to tanks which are operational but are simply idle.

2) When is the source required to install controls?

The facility must install the appropriate controls on the tank and be in compliance with the Chromium Electroplating MACT Standard when the tank commences operation.

3) When is the source required to conduct its performance test?

Section 63.7(a)(2)(iii) requires the facility to conduct a performance test on the tank within 180 days of startup as an affected facility.

4) What emission limit is the source subject to when it recommences operation?

The Part 63 General provisions defines "New source" as "any affected source the construction or reconstruction of which is commenced after the Administrator first proposes a relevant emission standard under this part." Consequently, the tanks applicability to the new or existing source emission limit when it commences operation will depend on the tanks date of construction or reconstruction. If the source meets the definition of reconstruction (the fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable new source), then it is subject to the new source emission limitation. Otherwise, it is subject to the existing source emission limitation.

 

5) If the source is a hard chrome tank, when must it have federally-enforceable restrictions in place to classify itself as a small chrome plater?

To classify itself as a small plater, the facility must have federally enforceable restrictions in place at the time the tank commences operation as an affected facility.

6) What are the initial notification requirements?

Section 63.347(b) requires facilities to meet the reporting requirements of §63.347, including initial notification, when the source becomes subject to the Chromium Electroplating MACT Standard. The Chromium Electroplating MACT Standard did not specify a time by which shutdown facilities that commence operation after the compliance date must submit an initial notification. However, to be consistent with the notification provisions in §63.9, these sources should submit their initial notification no later than 120 days after commencing operation. In addition, §63.347(d)(1) requires the facility to submit a notice of intent to conduct a performance test at least 60 days before the performance test is scheduled to begin and to report its compliance status under §63.347(e).