### COMPLIA NCE EVALUATION REPORT ON
- SITE I

NSPECTION Date of Inspection: July 28 , 20 10 Date of Report: July 28 , 20 10 Source Name: Crown Plating, Inc. SWCAA ID No.: 1848 Physical Location: 4221 N.E. St. Johns Rd., Unit G

Vancouver, WA 98661 Mailing Addre ss: 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 AO P No. N/A ADP : 93
- 1521R1 SWCAA Rep: Natalia Kreitzer Previous Inspection: July 28 , 200 9 Safety Equip.: None required. Eye glasses, safety shoes suggested Emission Inv. Year: 200 9 Emission Units: 1 200 9 Annual Emissions Potential to Emit (PTE ) Criteria Emissions: VOC
- 0. 06 tpy 0.25 tpy

NO x - 0.00 tpy 0.00 tpy CO
- 0.00 tpy 0.00 tpy PM
- 0.00 tpy <0.01 tpy PM 10 - 0.00 tpy <0.01 tpy PM 2.5 - 0.00 tpy <0.01 tpy SO 2 - 0.00 tpy 0.00 tpy TAP Emissions:
- 0. 0 6 tpy 0.25 tpy HAP Emis sions:
- 0. 0 5 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. S urface area of 2 ft2 and volume of 68.4 liters. Rectifier cap acity 150 Amps. Equipped with MesaWest Amp
-hour accumulator s/n not available
. b. Chrome plating tank #2. S urface area of 6 ft2 and volume of 342 liters. Rectifier capacity 100 Amps. Equipped with MesaWest Amp
-hour accumulator, s/n not available
. c. Chrome pl ating tank #3. S urface area of 8 ft2 and volume of 456 liters. Rectifier capacity 200 Amps. Equipped with Process Technology Amp
-hr accumulator s/n not available
. d. Chrome plating tank #4. S urface area of 12 ft2 and volume of 1,520 liters. T ank rectifier rated for 4,000 Amps. Equipped with Chemithon Amp
-hr accumulator, serial # EG 135 1996. e. Chrome plating tank #5. S urface area of 8 ft2 and volume of 456 liters. Rectifier capacity 300 Amps. Equipped with Process Technology Amp
-hr accumulator serial no. K81
- 366899. f. Chrome plating tank #6. S urface area of 8 ft2 and volume of 456 liters. Rectifier capacity 300 Amps. Equipped with Process Technology Amp
-hr accumulator, serial no. IG1
- 365239. g. Chrome plating tank #7. S urface area of 8 ft2 and volume of 684 liters. Rectifier capacity 700 Amps. Equipped with Process Technology Amp
-hr accumulator , s/n not available
. h. Chrome plating tank #8. S urface area of 36 ft2 and volume of 2,228 liters. T ank 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 C lemco 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 , 20 10
. B e fore 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 . T here 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 ne cessary 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 Inspecti on (in.) Foam Lock Solution

(Cups used during 200 9 ) Amp
-hrs

( Last Inspection) Amp
-hrs

( This Inspection) Tank 1 Not operating 37.5 225,392 2 55 , 991 Tank 2 Not operating 0 034,597 03 9, 604 Tank 3 >2 94 876,365 9 28,929 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. Reporti**  **ng/Records Review:** SWCAA received the annual compliance status report from Crown Plating on February 2 3 , 200 9
. A check of the operations and maintenance log at the facility showed that all required record keeping was up to date. T he emissions from the 20 0 9 process numbers in the compliance status report are shown in section E below. **E. Annual Emissions**  **:** The Emission Inventory for 200 9 emissions was received February 2 2 , 20 10
. P lating operation and product purchases were reported by Crown Plating. Emi ssions 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 = 0.0 2 lbs Cr VOC emissions from ZEP brake wash are based on 200 9 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 Me thanol* =5% x 0. 057 tons = 0.00 3 tons IPA =10% x 0. 057 tons = 0.0 06 tons Hex ane* = 85% x 0. 0 5 7 tons = 0.0 48 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 viol ations of any provisions of SW C AA 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 detail ed 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 com pliance 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** 

**Per mit**  **Permit App. Da** **te Issued Description** 

**_________________** 93
- 1521 CL
- 986 March 3, 1994 Approved h ard 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 Perm** **it Lim it/Requirem**  **ents 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: 0.0 2 lbs operations b. Emissions of volatile organic compounds Shall not exceed 500 lb s/yr 1 14 lb s/yr in 200 9 (VOCs) from cleaning of parts prior to chrome plating
c. Opacity (not to exce ed 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 Individual ly 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 us e 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 insp ection plating operations or w

hen windows to plating operation are open b. Chrome plating operations Mist suppressant in use during plating T anks 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 w

henever electrical and operating on all tanks current is applied to tank**Perm it Lim** **it/Requirem ents**  **I nspection Notes**  2. Operating Limitations (continued): d. VOC containing material used to clean Collected in a closed container S olvent 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 Re quirements :
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. Amp ere -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 ups ets Record of any upsets or breakdow ns OK, none since last in spection 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**Perm it Lim** **it/Req uirem** **ents 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 2 2 , 20 10 SWCAA by March 15 for previous year b. Consumption of chromic acid and other Calculated and submitted annually to Received February 2 2 , 20 10 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 pre cautions 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.**Perm it Lim** **it/Requirem ents**  **Inspection Notes** 6. 40 CFR 63 Subpart N: compliance (con’t) : b. 342(c)(2)(i) Small Chrome Facility One that is l ess than 60 million amp
-hr/yr. Test conducted at maximum rate of1 554 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 p lan with a follow up letter within seven working days.
e. 343(b) Initial test to demonstrate initial compliance. Crow n 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 info rmation 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 u

nless excess emissions report wa s submitted on February duration is 1% or greater than the time for 2 2 , 200 9 by Crow n Plating the reporting period
. No excess emissions reported.

### 4 **0 CFR 6**  **3 .**  **11504 Subpart**  **WWWWWW “**  **National Emission St andards for Hazardous Air** 

**Pollutants: Area Source Standards for Plating and Polishing Operations ”**  **Citation Requirem** **ent Inspector’s Observation**  40 CFR 6 3
. 11507 ( e) , 40 CFR 63.11508 (c)(8)(i) If you own or operate an affected new or existing dry mechanical po lishing 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.

40 CFR 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 40 CFR 63.11507 (e)(2) , 40 CFR 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.

40 CFR 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 40 CFR 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 opera

ting instructions. No malfunctions or failures reported

40 CFR 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. Notif ication 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. Include d 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 Requirem** **ent 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 b e 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 , 20 10

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 S WCAA staff on July 28 , 20 10
. This document contains a summary o f your facility's emission units and annual emissions, observations from SWCAA's inspection, applicable requirements/emission limits, and a compliance summary f or the facility

including identification of any violations, which were found. Iti s your ongoing responsibility to maintain continuous compliance with all of the applicable air pollution control requirements for your facility a s defined and referenced in SWCAA's regulations (400 through 493) and any S WCAA Air Discharge Permits which have been issued for your facility, as well as any s tate (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

### An **nual Compliance Report 1** 

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 Poli shing 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 f or 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 op erated 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 31 st of the year immediately following the reporting period and kept in a readily
- accessible location for review for a minimum of 5 years.