Electrolizing Corporation of Ohio (ECO) operates four hexavalent chromium-electroplating tanks at its Cleveland, Ohio facility. Emissions from these tanks vent to two three-stage composite mesh-pad systems with mist eliminators (System 1 and 2). EPA?s investigation uncovered noncompliance with the provisions of 40 C.F.R. Part 63, Subpart N, the National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks. EPA issued Finding of Violation (FOV) to EPC on July 28, 2015. Violations alleged in the FOV include: 1) failure to monitor and record the pressure drop across Systems 1 and 2 on 41 and 10 days, respectively; and 2) failure to operate and maintain the systems and the tanks associated with those systems in a manner consistent with good air pollution control practices on those days.
ECO achieved compliance with the requirement to monitor and record the pressure drop across its composite mesh-pad systems when it repaired these systems so that each stage was able to generate a pressure drop reading. This occurred on March 27, 2014 for System 1 and on March 19, 2012 for System 2. In addition, ECO has implemented procedures to prevent such a situation from reoccurring, including requiring immediate notification of management if an operator observes a problem with the subject equipment, installing an additional monometer to confirm operation of the pressure drop gauges, and installing insulation around t