I recommend that you issue a unilateral administrative order (AO) to Hard Chrome Plating Company (Hard Chrome) of Grand Rapids, Michigan. The AO requires Hard Chrome to produce specified information, including documents pertaining to its emissions control system and to permitting. The AO further requires that Hard Chrome undertake performance testing of its mesh pad mist eliminators and packed bed scrubbers using test methods specified in the AO.
Hard Chrome Plating Company (Hard Chrome) owns and operates a chromium-plating facility at 1516 Blaine Avenue SE, Grand Rapids, Michigan. On March 29, 2011, the Michigan Department of Environmental Quality (MDEQ) issued a Violation Notice (VN) to Hard Chrome citing violations of the National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks at 40 C.F.R. Part 63, Subpart N. On May 10, 2011, MDEQ issued another VN to Hard Chrome for its failure to respond to the first one, and then another on September 28, 2011 for its failure to conduct performance testing, which MDEQ had demanded in the first VN. MDEQ eventually sent Hard Chrome a �final opportunity� letter to enter into an agreement by December 20, 2012, to which the company did not respond. Not long after, MDEQ requested that the U.S. Environmental Protection Agency issue an information request to Hard Chrome. Accordingly, on April 23, 2013, EPA issued a Request for Information to Hard Chrome pursu