The facility upgraded its control systems (mainly mesh pads systems) to further reduce chromium emissions. Emission reductions are currently based on estimated values comparing failed stack tests and compliant stack testing performed after the initial FOV was issued. The ACO requires additional stack testing which will provide emission rates based on operational limitations and upgraded control systems to provide a more accurate emission reduction. Since this testing is part of the requirements of the ACO, the latest emission rates are currently not available but expected to be even more than the estimate provided above. Additionally, while 18.5 pounds/year reduction in a pollutant may not seem substantial, this particular polllutant (Chromium) is a highly toxic pollutant. We are currently working to identify risk and other health benefits resulting from this emission reduction.
CASE SUMMARY: This ACO resolves alleged violations of the Chrome MACT (40 C.F.R. Part 63, Subpart N). The alleged violations include exceeding the applicable emission limits based on stack testing, failure to monitor pressure drop across the entire control system, failure to maintain certain records, and failure to submit certain notifications. The ACO establishes operational limitations on each of the 7 open top hard chromium electroplating tanks at the facility designed to assure compliance with applicable limitations. It also requires continuous operation of upgraded control equipmen