COMPLIANCE EVALUATION REPORT

ON-SITE INSPECTION

Date of Inspection: July 28, 2010 Date of Report: July 28, 2010

Source Name: Crown Plating, Inc.

SWCAA ID No.: 1848

Physical Location: 4221 N.E. St. Johns Rd., Unit G

Vancouver, WA 98661

Mailing Address: Same as above

Telephone: (360) 693-3040

Fax: (360) 693-5777

Source Contact(s): Bill Furniss - General Manager

Inspection Contact: Bill Furniss - General Manager

AIRS No.: 53-011-00153 Title V No; Opt-Out No

SIC and/or NAICS: 3471/332813 AOP No. N/A

ADP: 93-1521R1

SWCAA Rep: Natalia Kreitzer

Previous Inspection: July 28, 2009

Safety Equip.: None required. Eye glasses, safety shoes suggested

Emission Inv. Year: 2009

Emission Units: 1

2009 Annual Emissions Potential to Emit (PTE)

Criteria Emissions: VOC - 0.06 tpy 0.25 tpy

NOx - 0.00 tpy 0.00 tpy

CO - 0.00 tpy 0.00 tpy

PM - 0.00 tpy <0.01 tpy

PM10 - 0.00 tpy <0.01 tpy

PM2.5 - 0.00 tpy <0.01 tpy

SO2 - 0.00 tpy 0.00 tpy

TAP Emissions: - 0.06 tpy 0.25 tpy

HAP Emissions: - 0.05 tpy 0.25 tpy

A. Process Description/Background: 

Crown Plating conducts hard chromium electroplating using hexavalent chromium in its plating tank 

solutions. This facility is an NESHAP source subject to 40 CFR 63 Subpart N of the National Emission 

Standards for Hazardous Air Pollutants for hard and decorative chromium electroplating and chromium 

anodizing facilities and 40 CFR 63 Subpart WWWWWW “National Emission Standards for Hazardous 

Air Pollutants: Area Source Standards for Plating and Polishing Operations”. 
B. Emission Units/Control Equipment Descriptions:

Emission Unit 1: Plating Operations: 8 tanks and supporting areas in building units G and H

a. Chrome plating tank #1. Surface area of 2 ft2and volume of 68.4 liters. Rectifier capacity 150 Amps. 

Equipped with MesaWest Amp-hour accumulator s/n not available.

b. Chrome plating tank #2. Surface area of 6 ft2and volume of 342 liters. Rectifier capacity 100 Amps. 

Equipped with MesaWest Amp-hour accumulator, s/n not available.

c. Chrome plating tank #3. Surface area of 8 ft2and volume of 456 liters. Rectifier capacity 200 Amps. 

Equipped with Process Technology Amp-hr accumulator s/n not available.

d. Chrome plating tank #4. Surface area of 12 ft2and volume of 1,520 liters. Tank rectifier rated for 

4,000 Amps. Equipped with Chemithon Amp-hr accumulator, serial # EG 135 1996.

e. Chrome plating tank #5. Surface area of 8 ft2and volume of 456 liters. Rectifier capacity 300 Amps. 

Equipped with Process Technology Amp-hr accumulator serial no. K81-366899.

f. Chrome plating tank #6. Surface area of 8 ft2and volume of 456 liters. Rectifier capacity 300 Amps. 

Equipped with Process Technology Amp-hr accumulator, serial no. IG1-365239.

g. Chrome plating tank #7. Surface area of 8 ft2and volume of 684 liters. Rectifier capacity 700 Amps. 

Equipped with Process Technology Amp-hr accumulator, s/n not available.

h. Chrome plating tank #8. Surface area of 36 ft2and volume of 2,228 liters. Tank rectifier rated for 

4,000 Amps. Equipped with Chemithon Amp-hour accumulator, serial # EG 135 1995.

The building exhausts through a custom filter system with a 24” by 24” Flanders Precision Aire Inc. 

furnace type pleated filter with an ASHRAE rating of Merv 8 filter through a 1.5 ft diameter stack, 22 ft 

above ground level. 

Additional Equipment: One polishing machine controlled by an internally exhausting custom filter 

system with a 24” by 24” Flanders Precision Aire Inc. furnace type pleated filter with an ASHRAE rating 

of Merv 8. One internally venting Clemco Mini-Hone Dry Blast Cabinet model number MCY-2232, 

serial number 1253 with cyclone and filter system.

C. Observations During Inspection

I went to Crown Plating, Inc. for an unannounced inspection on July 28, 2010. Before I entered the 

facility, I observed the bay doors and the installed airflow indicator ribbons. One bay door was open the 

day of the inspection, and the ribbons were hanging with an occasional inward movement. There were 

no nuisance odors or opacity observed outside the building. I met with Mr. Furniss who accompanied me

on the inspection. The inspection focused on the plating tanks and record keeping at the facility. 

Plating is performed in one of eight plating tanks. Foam Lock, a fume suppressant, is added to the tanks 

as necessary to maintain a foam depth of greater than 1”. 

Chrome plating tanks #3, #4, #5 and #6 were operating during the inspection. The facility was plating 

irrigation seals for irrigation piping. All non operating tanks were properly covered and no open 

containers of volatile substances were observed. There were no significant events at the facility since the 

previous inspection.
Table 1. Readings obtained for the tanks during the inspection and the annual report.

Tank ID

Foam Height 

During Inspection 

(in.)

Foam Lock Solution

(Cups used during 

2009)

Amp-hrs

(Last Inspection)

Amp-hrs

(This Inspection)

Tank 1 Not operating 37.5 225,392 255,991

Tank 2 Not operating 0 034,597 039, 604

Tank 3 >2 94 876,365 928,929

Tank 4 >2 603 247,704 312,834

Tank 5 Not operating 82.5 178,551 173,641

Tank 6 Not operating 48 079,035 565,978

Tank 7 Not operating 108.5 968,614 208,494

Tank 8 Not operating 436 705,800 961,939

Totals 1410

A used dry blast cabinet was also installed since the last inspection. The unit contains a cyclone and 

filter system and exhausts inside the polishing area. Mr. Furniss stated that this unit is used to remove 

rust or impurities off of parts prior to plating. It is not used on chrome plated or stainless steel parts.

D. Reporting/Records Review:

SWCAA received the annual compliance status report from Crown Plating on February 23, 2009. A 

check of the operations and maintenance log at the facility showed that all required record keeping was 

up to date. The emissions from the 2009 process numbers in the compliance status report are shown in 

section E below.

E. Annual Emissions:

The Emission Inventory for 2009 emissions was received February 22, 2010. Plating operation and 

product purchases were reported by Crown Plating. 

Emissions are calculated below based on an emission factor of 0.0149 lb/MMAmp-hrs from a source test 

completed December 22, 1998.

1,494,502 Amp-hr/yr * 0.0149 lbs of total Cr/per million Amp-hrs = 0.02 lbs Cr

VOC emissions from ZEP brake wash are based on 2009 usage of 20 gallons. The specific gravity of the 

product is 0.68 according to an MSDS on file.

VOCs 20 gal/yr * (0.68* 8.34 lbs/gal) / (2,000 lb/ton) = 0.057 tons

Methanol* =5% x 0.057 tons = 0.003tons

IPA =10% x 0.057 tons = 0.006 tons

Hexane* =85% x 0.057 tons = 0.048 tons *HAP

F Compliance Assessment with Applicable Requirements/Emission Limits: 

See Appendix II of this document.

G. Compliance Summary:

Crown Plating is subject to 40 CFR 63 Subpart N: Chromium Electroplating NESHAP compliance 

requirements. No violations of any provisions of SWCAA 400, MACT standards or applicable Air 

Discharge Permits were observed during the review of the reported information or inspection of the 

Crown Plating, Inc. facility. See Appendix II for a detailed description.
Crown Plating is also subject to 40 CFR 63 Subpart WWWWWW “National Emission Standards for 

Hazardous Air pollutants: Area Source Standards for Plating and Polishing Operations” because the 

facility does perform dry mechanical polishing of plated parts. The compliance date for this subpart was 

July 1, 2010. Appendix I also details this subpart.

H. Appendices and Attachments:

I Regulatory Permit Summary

II Compliance Assessment

III Photographs
Appendix I

Regulatory Permit Summary

Permit Permit App. Date Issued Description _________________

93-1521 CL-986 March 3, 1994 Approved hard chrome plating 

operations

93-1521R1 CL-1410 September 6, 2000 Modification of 93-1521 to allow single 

roll up door to be open during plating 

operations. Superseded SWCAA 93-

1521.
Appendix II

Compliance Summary

Permit Limit/Requirements Inspection Notes

1. Emission Limitations:

a. Emissions of hexavalent chromium Control efficiency > 95 percent; Control Eff. is 98%

(Cr[VI]) from total chrome plating Emissions less than 2.2 lbs/yr Emissions: 0.02 lbs

operations

b. Emissions of volatile organic compounds Shall not exceed 500 lbs/yr 114 lbs/yr in 2009

(VOCs) from cleaning of parts prior to 

chrome plating

c. Opacity (not to exceed for 3 minutes in Zero percent no visible emissions observed

any one hour period) as measured by a during inspection

Certified Observer in accordance with 

40 CFR 60, Appendix A.

d. Emissions of other toxic air pollutants Individually shall not exceed the SQER TAPs<SQER (as in effect 8/21/1998)

(TAP) as defined in WAC 173-460 (Small Quantity Emission Rate) 

Table A, WAC 173-460; Collectively 

shall not exceed limit in 1.b.

e. Emissions to atmosphere which can cause Shall use good practice and procedures No odors observed during

odors or contribute to a nuisance odor to keep odors to a reasonable minimum. inspection

2. Operating Limitations:

a. Exhaust Fan Shall be operated at all times during operating during inspection

plating operations or when windows to 

plating operation are open

b. Chrome plating operations Mist suppressant in use during plating Tanks not in use covered

tank operations; tanks covered when See Sec. C for foam heights

current is not applied on working tanks.

c. Ampere-hour accumulators Installed on each tank rectifier: must be Accumulators installed 

operating properly whenever electrical and operating on all tanks 

current is applied to tank
Permit Limit/Requirements Inspection Notes

2. Operating Limitations (continued):

d. VOC containing material used to clean Collected in a closed container Solvent containers closed

metal parts

e. Containers for storage, transfer, and Stored in a closed container No open containers observed

disposal of VOC containing materials 

including solvent rags and paper

f. Door openings Only one roll up door may be open during 1 door up during inspection

plating. All airflow must be into the with inwardly moving ribbons

building at all times during plating. 

g. Ribbons on doors Shall be installed at roll up door openings OK, ribbons still present

to indicate the direction of airflow. Shall 

18” ribbons, 3 per side and top of opening

3. Monitoring/Recordkeeping Requirements:

a. Operation and maintenance (O/M) log Shall be maintained and shall contain date OK, log current

and name of person making each entry and 

description of activity

b. Chrome plating tank maintenance, Logged for each occurrence OK, information in log

replenishment, and tank solution changes

c. Foam suppressant thickness Logged every hour for first 40 hours, Foam thickness logged each hour

logged every 4 hours for next 40 hours, 

logged every 8 hours thereafter unless 

limit exceeded

d. Ampere-hour accumulator readings Daily readings of total ampere-hours from Amp-hrs recorded daily

the accumulator and the daily total utilized 

in each tank ; 

e. Process upsets Record of any upsets or breakdowns OK, none since last inspection

f. Mist suppressant used Frequency and quantity of additions of Recorded for each addition

approved mist suppressants 

(FOAM-LOK L)

g. Inventory of chemical products on hand Documented monthly OK, tracked by invoice
Permit Limit/Requirements Inspection Notes

3. Monitoring/Recordkeeping Requirements (continued):

h. Purchase receipts and MSDSs for all Documented for each purchase OK, kept on file in office

i. All records required Maintained retrievable for 3-year min. Maintained onsite in office

4. Reporting Requirements:

a. Emissions to the atmosphere Calculated and submitted annually to Received February 22, 2010

SWCAA by March 15 for previous year

b. Consumption of chromic acid and other Calculated and submitted annually to Received February 22, 2010

Chemical plating related products SWCAA by March 15 of the following year

c. Upset conditions Reported to SWCAA via telephone in No upsets reported

accordance with SWCAA 400-107

5. General Standards SWCAA 400-040:

a. Visible emissions 20% opacity limit, all non-specified No opacity observed

sources

b. Fallout No emission of particulates that settle No fallout observed

beyond property

c. Fugitive emissions Reasonable precautions to prevent No fugitive emissions observed

d. Odors Shall use recognized good practice and No odor observed

procedures to reduce odors to a minimum 

e. Detrimental emissions Prohibited None detected

f. Concealment and masking of emissions Prohibited None detected

6. 40 CFR 63 Subpart N: Chromium Electroplating NESHAP compliance: (some compliance from previous report)

a. 342(c)(1)(ii) Emission standard 0.03 mg of chromium per dscm (dry Total conc. was 0.0027

standard cubic meter) mg/dscm during 1998 test.
Permit Limit/Requirements Inspection Notes

6. 40 CFR 63 Subpart N: compliance (con’t):

b. 342(c)(2)(i) Small Chrome Facility One that is less than 60 million amp-hr/yr. Test conducted at maximum rate of1554 

amp-hour (13.6 million amp- hr/yr). The 

facility meets the small chrome facility 

definition.

c. 342(f)(3) Work practice standards Operations and maintenance plan. O and M procedures were incorporated into 

the SWCAA Air Discharge Permit.

d. 342(f)(3)(iii) Work practice standards A phone report shall be submitted within OK, none since last inspection

recordkeeping. two working days after periods of 

malfunction that are inconsistent with the 

operations and maintenance plan with a 

follow up letter within seven working days. 

e. 343(b) Initial test to demonstrate initial compliance. Crown Plating submitted report on January 

27, 1999

f. 343(b)(6) Methods to demonstrate continuous Incorporated into permit 

compliance requirements (see above) 

h. 344 Initial performance test: The performance test was conducted on 

12/22/98 with the report submitted to 

SWCAA on 1/27/99.

i. 346(a) Recordkeeping requirements Records shall be maintained for inspection, OK, all information current

maintenance, malfunctions and actions 

taken, and suppressant additions 

j. 347(h) Ongoing compliance status reports. Ongoing compliance status reports shall be The compliance certification 

submitted yearly unless excess emissions report was submitted on February

duration is 1% or greater than the time for 22, 2009 by Crown Plating

the reporting period. No excess emissions reported.
40 CFR 63.11504 Subpart WWWWWW “National Emission Standards for Hazardous Air 

Pollutants: Area Source Standards for Plating and Polishing Operations” 

Citation Requirement Inspector’s Observation

40CFR 63.11507(e), 40CFR 

63.11508 (c)(8)(i)

If you own or operate an affected new or existing dry mechanical 

polishing equipment that emits one or more of the plating and polishing 

metal HAP, you must operate a capture system that captures particulate 

matter (PM) emissions from the dry mechanical polishing process and 

transports the emissions to a cartridge, fabric or high efficiency 

particulate air (HEPA) filter.

Crown Plating does utilize a custom 

internally exhausted capture system 

with a Merv 8 pleated filter.

40CFR 63.11507 (e)(1),

40CFR 63.11508(d)(4)(i)

You must operate all capture and control devices according to the 

manufacturer’s specifications and operating instructions.

Since this device is a custom unit, 

Crown Plating has produced an 

operating manual for the unit and is 

complying with the manual

40CFR 63.11507 (e)(2), 

40CFR 63.11508 (c)(8)(iii), 

40CFR 63.11508(d)(4)(v)

You must keep the manufacturer’s specifications and operating 

instructions at the facility at all times in a location where they can be 

easily accessed by the operators.

Operating manual kept onsite.

40CFR 63.11508 (c)(8)(ii) You must state in your Notification of Compliance Status that you have 

installed the control system according to the manufacturer’s 

specifications and instructions.

Notification of Compliance 

received February 22, 2010 and 

indicates the facility is in 

compliance

40CFR 63.11508(d)(4)(ii) Following any malfunction or failure of the capture or control devices to 

operate properly, you must take immediate corrective action to return 

the equipment to normal operation according to the manufacturer’s 

specifications and operating instructions.

No malfunctions or failures 

reported 

40CFR 63.11508(d)(4)(iii) You must state in your annual certification that you have operated and 

maintained the control system according to the manufacturer’s 

specifications and instructions.

Notification of Compliance 

received February 22, 2010 and 

indicates the facility is in 

compliance

40CFR 63.11508(d)(4)(iv) You must record the results of all control system inspections, deviations 

from proper operation, and any corrective action taken.

Included in maintenance log

40CFR 63.11509(a) ....You must submit an Initial Notification no later than 120 days after 

July 1, 2008 and shall include a description of the compliance method 

for each affected source.

Copy of initial notification received 

October 14, 2008

40CFR 63.11509(b) ...You must submit a Notification of Compliance Status before July 1, 

2010 and shall include a list of affected sources and the plating and 

polishing metal HAP used in, or emitted by, those sources; methods 

used to comply with the applicable management practices and 

equipment standards; description of the capture and emission control 

system used to comply with the applicable equipment standards; and 

statement by the owner or operator of the affected source as to whether 

the source is in compliance with the applicable standards or other 

requirements.

Notification of Compliance 

received February 22, 2010 and 

indicates the facility is in 

compliance
Citation Requirement Inspector’s Observation

40CFR 63.11509(c) ...You must prepare an annual certification of compliance report no 

later than January 31 of the year immediately following the reporting 

period and kept in a readily accessible location for inspector review. 

These reports do not need to be submitted unless a deviation from the 

requirements of this subpart has occurred. The report shall include that 

you have operated and maintained the control system according to the 

manufacturer’s specifications and instructions

First annual certification to be 

completed by January 31, 2011

40CFR 63.11509(d) ...You must report any deviations, along with the corrective action 

taken, and submit this report to the delegated authority.

No deviations reported 

40CFR 63.11509(e) ...You must keep the records specified for a minimum of 5 years. 

Records must be kept onsite for at least 2 years but may be kept offsite 

for the remaining 3 years.

Records kept onsite 
Appendix III

Photographs 

Plating Area

Plating Tanks 1 & 2

Tank 3

Tanks 5 & 6
Polisher and Polishing Filter Blast Cabinet
July 28, 2010

Mr. Bill Furniss – General Manager

Crown Plating, Inc.

4221 N.E. St. Johns Road Unit G

Vancouver, WA 98661

Dear Mr. Furniss:

The enclosed inspection report summarizes the Southwest Clean Air Agency's (SWCAA) 

findings from our most recent periodic inspection of your facility. This inspection was conducted 

by SWCAA staff on July 28, 2010. This document contains a summary of your facility's 

emission units and annual emissions, observations from SWCAA's inspection, applicable 

requirements/emission limits, and a compliance summary for the facility including identification 

of any violations, which were found. It is your ongoing responsibility to maintain continuous 

compliance with all of the applicable air pollution control requirements for your facility as 

defined and referenced in SWCAA's regulations (400 through 493) and any SWCAA Air 

Discharge Permits which have been issued for your facility, as well as any state (WAC 173) and 

federal (40 CFR) regulations which apply. 

Please review this document carefully and note that any information contained within it is 

considered public domain and not confidential. If you find any discrepancies or have any

questions, please contact me at (360) 574-3058 extension 14. 

Sincerely,

Natalia Kreitzer

Air Quality Engineer
Annual Compliance Report1

The facility has operated in compliance with all of the relevant standards and other requirements of 40 

CFR Part 63 subpart WWWWWW, National Emission Standards for Hazardous Air Pollutants: Area 

Source Standards for Plating and Polishing Operations during the past reporting year. In addition, I have 

operated and maintained the polishing filter system according to the operating and maintenance plan. No 

deviations have occurred during the reporting year.

__________________________________ _______________________________

 (Signature) (Date)

The facility has operated in compliance with all of the relevant standards and other requirements of 40 

CFR Part 63 subpart WWWWWW, National Emission Standards for Hazardous Air Pollutants: Area 

Source Standards for Plating and Polishing Operations during the past reporting year. In addition, I have 

operated and maintained the polishing filter system according to the operating and maintenance plan. No 

deviations have occurred during the reporting year.

__________________________________ _______________________________

 (Signature) (Date)

The facility has operated in compliance with all of the relevant standards and other requirements of 40 

CFR Part 63 subpart WWWWWW, National Emission Standards for Hazardous Air Pollutants: Area 

Source Standards for Plating and Polishing Operations during the past reporting year. In addition, I have 

operated and maintained the polishing filter system according to the operating and maintenance plan. No 

deviations have occurred during the reporting year.

__________________________________ _______________________________

 (Signature) (Date)

The facility has operated in compliance with all of the relevant standards and other requirements of 40 

CFR Part 63 subpart WWWWWW, National Emission Standards for Hazardous Air Pollutants: Area 

Source Standards for Plating and Polishing Operations during the past reporting year. In addition, I have 

operated and maintained the polishing filter system according to the operating and maintenance plan. No 

deviations have occurred during the reporting year.

__________________________________ _______________________________

 (Signature) (Date)

 

1 Must be completed no later than January 31st of the year immediately following the reporting period and kept in a 

readily-accessible location for review for a minimum of 5 years.