**TECHNICAL SUPPORT DOCUMENT Air Discharge Permit ADP 02**  **- 2442R1**  **ADP Application CL -**  **1650** 

### Pacific Northwest Plating, Inc. **SWCAA ID 2118 Final Date:**  

### October 20, 2004

Prepared By: Natalia Kreitzer

Air Quality Engineer Southwest Clean Air AgencyTechnical Support Document ADP Application CL - 1650 Pacific Northwest Plating, Inc. ADP 02 -2442R1 **TABLE OF CONTENTS** Section Page 1. Facility Identification 1 2. Facility Description 1 3. Current Permitting Action 1 4. Process Description 2 5. Equipment/Activity Identification 2 6. Emissions Determination 2 7. Regulations and Emission Standards 7 8. RACT/BACT/BART/LAER/PSD/CAM Determinations 6 9. Am bient Impact Analysis 6 10. Discussion of Approval Conditions 7 11. Start-up and Shutdown Provisions/Alternative Operating Scenarios/P ollution Prevention 8 12. Emission Monitoring and Testing 8 13. Facility History 8 14. Public Notice/Comment 8Technical Support Document ADP Application CL - 1650 Pacific Northwest Plating, Inc. ADP 02 -2442R1 **Abbreviations** ADP Air Discharge Permit AP -42 Compilation of Emission Factors, AP -42, Fifth Edition, Volume 1, Stationary Point and Area Sources

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published by the US Environmental Protection Agency BACT Best available control technology BART Best Available Retrofit Technology Btu British thermal unit CFR Code of Federal Regulations EPA U.S. Environmental Protection Agency gr/dscf Grains per dry standard cubic foot (68 °F, 1 atmosphere) H2 SO 4 Sulfuric acid HAP Hazardous air pollutant listed pursuant to Section 112 of the Federal Clean Air Act HCl Hydrochloric acid LAER Lowest achievable emission rate MSDS Material Safety Data Sheet NaOH Sodium hydroxide NOV Notice of Violation PSD Prevention of Significant Deterioration RACT Reasonably Available Control Technology RCW Revised Code of Washington SQER Small Quantity Emission Rate listed in WAC 173 -460 SWCAA Southwest Clean Air Agency TAP Toxic air pollutant pursuant to Chapter 173 -460 WAC T -BACT Best Available Control Technology for toxic air pollutants tpy Tons per year WAC Washington Administrative CodeTechnical Support Document ADP Application CL - 1650 Pacific Northwest Plating, Inc. ADP 02 -2442R1

1 **1. FACILITY IDENTIFICATION** Applicant Name: Pacific NW Plating, Inc. Applicant Address: 7001 NE 40th Avenue, Vancouver, WA 98661 Facility Name: Pacific Northwest Plating, Inc. Facility Address: 7001 NE 40th Avenue, Vancouver, WA 98661 SWCAA Identification: 2118 Contact person: Anthony Sicilia Primary Process: Electroplating SIC/NAICS Code: 3471/ 332813 Facility Classification: Natural Minor **2. FACILITY DESCRIPTION** Pacific Northwest Plating, Inc (PNW Plating) is a metal finishing facility which includes electroplating of chromium, copper, nickel and zinc. **3. CURRENT PERMITTING ACTION** This permitting action is in response to Air Discharge Permit application number CL - 1650 (ADP Application CL - 1650) dated March 2, 2004. PNW Plating is relocating its electroplating facility from 7000 NE 40th Avenue, Suite A- 1, Vancouver, WA to 7001 NE 40th Avenue, Vancouver, WA. The following tanks will be relocated: 1. One chromic acid electroplating tank with a total surface area of 24 square feet (ft2) and a production capacity of 2,000 Amps. Emissions from t he chromic acid tank will be controlled with the use of Fumetrol #140 mist suppressant which operates by reducing the surface tension of the bath. One Amp -hour meter will be located on the chromic acid tank which will be non-resettable. 2. Two nickel electroplating tanks with a total surface area of 48 ft2 and a production capacity of 2,000 Amps. Emissions from the nickel tanks will be controlled with the use of a wetting agent which reduces surface tension and creates a foam blanket on the tank. One non-re settable Amp -hour meter serves both nickel electroplating tanks. 3. One copper cyanide electroplating tank with a total surface area of 24 ft2 and a production capacity of 1,000 Am ps. One non-resettable Amp -hour meter will be located on the copper cyanide electroplating tank. 4. One 6% sulfuric acid (H2 SO 4) tank with a maximum volume of 300 gallons used for cleaning parts prior to plating. 5. One sodium hydroxide soap (NaOH) tank with a maximum volume of 450 gallons. 6. Four recovery tanks for rinsing parts. In addition, PNW Plating is requesting approval for the addition of a zinc plating system consisting of the following: 1. One zinc electroplating tank with a total surface area of 24 square feet (ft2) and a production capacity of 2,000 Am ps. One Amp -hour meter will be located on the zinc tank which will be non-resettable. 2. One activator tank with a maximum volume of approximately 300 gallons used for activating the metal prior to plating. 3. One dye tank with a maximum volume of approximately 360 gallons used for protecting the product after plating. 4. One bright dip tank with a maxim um volume of approximately 355 gallons used for brightening the product after plating. 5. One 20 -25% hydrochloric acid (HCl) tank with a maximum volume of 400 gallons used for cleaning parts prior to plating. 6. One sodium hydroxide soap tank with a maximum volume of 450 gallons. 7. Four recovery tanks for rinsing parts. Emissions from this facility will exhaust via a 2 - foot square stack six feet above the roof level. ADP 02 -2442 will be superseded in its entirety by this permitting action.Technical Support Document ADP Application CL - 1650 Pacific Northwest Plating, Inc. ADP 02 -2442R1

2 **4. PROCESS DESCRIPTION** Electroplating involves the use of an electric current to apply metallic coatings to parts. The plating tank is filled with a solution containing metal ions which are deposited on the parts. The product is usually cleaned prior to electroplating and rinsed several times after. **5. EQUIPMENT/ACTIVITY IDENTIFICATION** 5.a Chromic Acid Electroplating Tank. One chromic acid electroplating tank with a total surface area of 24 square feet (ft2) and a production capacity of 2,000 Amps. Emissions from the chromic acid tank will be controlled with the use of Fumetrol #140 mist suppressant which operates by reducing the surface tension of the bath. One nonresettable Amp -hour meter is located on the chromic acid tank. 5.b Nickel Electroplating Tanks. Two nickel electroplating tanks with a total surface area of 48 ft2 and a production capacity of 2,000 Amps. Emissions from the nickel electroplating tanks will be controlled with the use of a wetting agent, Rohco Wetter, which reduces surface tension and creates a foam blanket on the tank. One non-resettable Amp hour meter serves both nickel electroplating tanks. 5.c Copper Cyanice Electroplating Tank. One copper cyanide electroplating tank with a total surface area of 24 ft2 and a production capacity of 1,000 Amps. One non-resettable Amp -hour meter is located on the copper cyanide electroplating tank. 5.d Zinc Electroplating System. This system includes one zinc electroplating tank with a total surface area of 24 ft2 and a production capacity of 2,000 Amps with a non-resettable Amp -hour meter, one HCl soap tank and one bright dip tank. **6. EMISSIONS DETERMINATION** 6.a Hexavalent Chromium. Hexavalent chromium emissions from the facility were estimated at 0.033 pounds per year based on 1,000,000 amp -hours and an emission factor of 0.033 pounds per million amp -hours from South Coast Air Quality Management District’s Source Test Report 95 -0027 “Efficiency Testing of Fumetrol 140 for Controlling Chromium Emissions from a Decorative Plating Tank.” 0.033 lb mi llion Am

p hr

 x 1,000,000 Amp -hr = 0.033 lb 

### yr Actual emissions will be calculated based on the above equation and actual annual amp -hours of plating activity. 6.b Nickel. Nickel emissions from the facility were estimated at 3.25 pounds per year based on 1,100,000 amp -hours and an emission factor of 2.88 pounds per million amp -hours. This emission factor is from EPA’s AP -42 section 12.20 “Electroplating” (7/96) for uncontrolled nickel electroplating and a control efficiency of 96.8 percent. The control efficiency is calculated based on the emission factors in EPA’s AP -42 section 12.20 “Electroplating” (7/96) for uncontrolled chromic acid anodizing and chromic acid anodizing with fume suppressant and was used to obtain a controlled nickel emissions factor of 2.88 pounds per million amp-hour. Emissions were estimated as follows: 2.88 lb mi llion Am

p hr

 x 1,100,000 Amp -hr = 3.25 lb 

### yr Actual emissions will be calculated based on the above equation and actual annual amp -hours of plating activity. 6.c Copper. Copper emissions from the facility were estimated at 96 pounds per year based on 1,460,000 amp -hours and an emission factor of 1.1 pounds per million amp -hours. This emission factor is from EPA’s AP -42 section 12.20 “Electroplating” (7/96) for uncontrolled copper electroplating. AP -42 only provides an emission factor for copper sulfate electroplating tank with a wet scrubber. The scrubber efficiency was estimated at 98.25 percent fromTechnical Support Document ADP Application CL - 1650 Pacific Northwest Plating, Inc. ADP 02 -2442R1

3 chromium emission factors with and without a scrubber and was used to obtain an uncontrolled copper emissions factor of 66 pounds per million amp -hour. Emissions were estimated as follows: 66 lb mi llion Am

p hr

 x 1,460,000 Amp -hr = 96 lb 

### yr Actual emissions will be calculated based on the above equation and actual annual amp -hours of plating activity. 6.d Cyanide. Cyanide emissions from the facility were estimated at 5. 6 pounds per year based on 1,460,000 amp -hours and an emission factor of 1.1 pounds per million amp-hours. This emission factor is from EPA’s AP -42 section 12.20 “Electroplating” (7/96) for uncontrolled copper electroplating. AP -42 only provides an emission factor for copper cyanide electroplating tank with a mesh pad mist eliminator. The mist eliminator efficiency was estimated at 99 percent from chromium emission factors with and without a mist eliminator and was used to obtain an uncontrolled cyanide emissions factor of 3.86 pounds per million amp -hour. Emissions were estimated as follows: 3.86 lb mi llion Am

p hr

 x 1,460,000 Amp -hr = 5.6 lb 

### yr Actual emissions will be calculated based on the above equation and actual a nnual amp -hours of plating activity. 6.e Zinc. Zinc emissions from the facility were estimated at 135 pounds per year based on 1.5 million amp -hours and an emission factor of 

### 90 pounds per million amp -hours from EPA’s AP -42 section 12.20 “Electroplating” (7/96) for uncontrolled nickel electroplating. Emissions were estimated as follows: 90 lb mi llion Am

p hr

 x 1,500,000 Amp -hr = 135 lb 

### yr Actual emissions will be calculated based on the above equation and actual annual am p -hours of plating activity. 6.f Methanol. Methanol is contained in the bright dip used in the zinc system. The bright dip contains methanol at a weight content of five to ten percent. This bright dip is used at a strength of 14 ounces per 100 gallons of water resulting in a final methanol concentration of 0.008 to 0.016 weight percent. Emissions of methanol from the facility were estimated to be 333 lb/yr based on a very conservative estimate that all methanol contained in the bright dip purchased will be emitted. PNW Plating estimated a maximum usage of 30 gallons per month of bright dip. Emissions are calculated as follows: 30 gal month x 9.27 lb

gal x 12 month

yr x 10% = 333 lb



### yr 6.g Hydrochloric Acid. Hydrochloric acid (HCl) is contained in a tank used in the zinc system at a weight content of 20 to 25 percent. Emissions of HCl from the facility were estimated to be 0.025 lb/hr based on the following equation: Q = 5 .10x10 - 6 * U0.78 * Pv * Mw0.67 * Ap 0.94 where Q is the emission rate in grams per second, U is the wind speed in meters per second, Pv is the vapor pressure in N/m 2 , Mw is the molecular weight and Ap is the surface area in square meters. A

vapor pressure of 289 N/m 2 was used in the equation and is based on Perry’s Chemical Engineering Handbook. A

conservative wind speed of 0.1 m/s was used. Assuming that the tank is covered 50 percent of the time, annual emissions of hydrochloric acid will be 110 pounds per year. Actual emissions will be calculated based on an emission factor of 0.025 lb/hr and the estimated annual hours that the tank is not covered.Technical Support Document ADP Application CL - 1650 Pacific Northwest Plating, Inc. ADP 02 -2442R1

4 6.h Sulfuric Acid and Sodium Hydroxide. Emissions of sulfuric acid from the facility were estimated to be negligible from the 6 percent by weight sulfuric acid tank based on the following equation: Q = 5.10x10 - 6 * U0.78 * Pv * Mw0.67 * Ap 0.94 where Q is the emission rate in grams per second, U is the wind speed in meters per second, Pv is the vapor pressure, Mw is the molecular weight and Ap is the surface area. Emissions were estimated at 2x10 - 13 pounds per year. Emissions of NaOH were estimated to be negligible based on the low vapor pressure of NaOH (NaOH is a solid at room temperature). **7. REGULATIO NS AND EMISSION STANDARDS**  Regulations that have been used to evaluate the acceptability of the proposed facility and establish emission limits and control requirements include, but are not limited to, the regulations, codes, or requirements listed below. 7.a Title 40 Code of Federal Regulations (CFR) 51.166(c) "Ambient air increments" requires approved State Implementation Plans to contain emission limitations and other measures as may be necessary to assure that increases in pollutant concentration over t he baseline concentration in areas designated as Class I, II, or III shall not exceed the incremental limits contained 40 CFR 51.166(c). 7.b Title 40 CFR 60.7 "Notification and Recordkeeping" requires that notification shall be submitted to SWCAA, the del egated authority, for date construction commenced, anticipated initial startup, and initial startup. 7.c Title 40 CFR 63.340 et seq. (Subpart N) "National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks" establishes conditions of operation for each chromium anodizing tank at facilities performing hard chromium electroplating, decorative chromium electroplating, or chromium anodizing. This facility performs decorative chromium electroplating and is subj ect to this regulation. This facility performs decorative chromium electroplating b ased on the thickness of the chromium layer electrodeposited and the Amperes per square meter and is subject to this regulation. D ecorative chromium electroplating facilities must either perform source testing to demonstrate that the concentration of total chromium in the exhaust gas does not exceed 4.4x10 - 6 gr/dscf or, if using a chemical fume suppressant containing a wetting agent, perform monitoring to demonstrate that the surface tension does not exceed 45 dynes per centimeter. 7.d Title 40 CFR Part 70 "State Operating Permit Programs" requires facilities with site emissions of any regulated air pollutant greater than 100 tpy, any single hazardous air pollutant greater than 10 tpy, and/or any aggregate combination of hazardous air pollutants greater than 25 tpy to obtain a Title V permit. 7.e Revised Code of Washington (RCW) 70.94.141 empowers any activated air pollution control authority to prepare and develop a comprehensive plan or plans for the prevention, abatement and control of air pollution within its jurisdiction. An air pollution control authority may issue such orders as may be necessary to effectuate the purposes of the Washington Clean Air Act [RCW 70.94] and enforce the same by all appropriate administrative and judicial proceedings subject to the rights of appeal as provided in Chapter 62, Laws of 1970 ex. sess. 7.f RCW 70.94.152 provides for the inclusion of conditions of operation as a re reasonably necessary to assure the maintenance of compliance with the applicable ordinances, resolutions, rules and regulations when issuing an Air Discharge Permit for installation and establishment of an air contaminant source. 7.g WAC 173 -401 "Opera ting Permit Regulation" requires all major sources and other sources as defined in WAC 173 - 401 -300 to obtain an operating permit. This regulation is not applicable because this source is not a potential major source and does not meet the applicability criteria set forth in WAC 173 -401 -300.Technical Support Document ADP Application CL - 1650 Pacific Northwest Plating, Inc. ADP 02 -2442R1

5 7.h WAC 173 -460 "Controls for New Sources of Toxic Air Pollutants" requires Best Available Control Technology for toxic air pollutants (T -BACT), identification and quantification of emissions of toxic air pollutants and demonstration of protection of human health and safety. 7.i WAC 173 -470 "Am bient Air Quality Standards for Particulate Matter" establishes ambient air quality standards for total suspended particulate matter and for particulate matter smaller than 10 microns (PM 10), which may not be exceeded more than one day per year. 7.j SWCAA 400 -040 "General Standards for Maximum Emissions" requires all new and existing sources and emission units to meet certain performance standards with respect to Reasonably Availa ble Control Technology (RACT), visible emissions, fallout, fugitive emissions, odors, emissions detrimental to persons or property, sulfur dioxide, concealment and masking, and fugitive dust. 7.k SWCAA 400 -040(1) "Visible Emissions" requires that no emiss ion of an air contaminant from any emissions unit shall exceed twenty percent opacity for more than three minutes in any one hour at the emission point, or within a reasonable distance of the emission point. 7.l SWCAA 400 -040(2) "Fallout" requires that no emission of particulate matter from any source shall be deposited beyond the property under direct control of the owner(s) or operator(s) of the source in sufficient quantity to interfere unreasonably with the use and enjoyment of the property upon which the material is deposited. 7.m SWCAA 400 -040(3) "Fugitive Emissions" requires that reasonable precautions be taken to prevent the fugitive release of air contaminants to the atmosphere. 7.n SWCAA 400 -040(4) "Odors" requires that any person who shall caus e or allow the generation of any odor from any source, which may unreasonably interfere with any other property owner's use and enjoyment of their property use recognized good practices and procedures to reduce these odors to a reasonable minimum. 7.o SWCAA 400 -040(8) "Fugitive Dust Sources" requires that reasonable precautions be taken to prevent fugitive dust from becoming airborne, and minimize emissions. 7.p SWCAA 400 -060 "Emission Standards for General Process Units" requires that all new and existing sources not emit particulate matter in excess of 0.1 grains per dry standard cubic foot of exhaust gas. 7.q SWCAA 400 - 110 "New Source Review" requires that an Air Discharge Permit Application be filed with SWCAA, and an Air Discharge Permit be issued by SWCAA, prior to establishment of the new source, emission unit, or modification. 7.r SWCAA 400 - 111 "Requirements for Sources in a Maintenance Plan Area" requires that no approval to construct or alter an air contaminant source shall be granted unless it is evidenced that: (1) The equipment or technology is designed and will be installed to operate without causing a violation of the applicable emission standards; (2) Emissions will be minimized to the extent that the new source will not exceed emission levels or other requirements provided in the maintenance plan; (3) Best Available Control Technology will be employed for all air contaminants to be emitted by the proposed equipment; (4) The proposed equipment will not cause any ambient air quality standard to be exceeded; and (5) If the proposed equipment or facility will emit any toxic air pollutant regulated under WAC 173 -460, the proposed equipment and control measures will meet all the requirements of that Chapter.Technical Support Document ADP Application CL - 1650 Pacific Northwest Plating, Inc. ADP 02 -2442R1

6 **8. RACT/BACT/BART/LAER/PSD/CAM DETERMINATIONS**  The proposed equipment and control systems incorporate Best Available Control Technology (BACT) for the types and amounts of air contaminants emitted by the processes as described below: 8.a Chromium Electroplating. The use of a fume suppressant which will reduce hexavalent chromium emissions by 99% from the chromium plating tank, reduce the surface tension below 45 dynes/cm and ensure no visible emissions meets the requirements of Best Available Control Technology (BACT) and Toxics BACT for decorative chromium electroplating facilities. 8.b Nickel Electroplating. The use of a wetting agent which will reduce nickel emissions by 96.8%, produce a foam blanket and ensure no visible emissions meets the requirements of Best Available Control Technology (BACT) and Toxics BACT for decorative chromium electroplating facilities. 8.c Copper Electroplating. The use of good work practice and visible emissions that are zero percent meets the requirements of BACT and Toxics BACT. 8.d Zinc Electroplating System. The use of good work practice and visible emissions that are zero percent meets the requirements of BACT and Toxics BACT for the zinc plating tank. The use of a cover on the hydrochloric acid tank associated with the zinc electroplating operations meets the requirements of BACT and Toxics BACT for this tank. 8.e Prevention of Significant Deterioration (PSD) Applicability Determination: This permitting action will not result in a potential increase in emissions equal to or greater than the PSD thresholds. Therefore, PSD review is not applicable to this action. 8.f Compliance Assurance Monitoring (CAM) Applicability Determination. CAM is not applicable to any emission unit at this facility because it is not a major source and is not required to obtain a Part 70 permit. **9. AMBIENT IMPACT ANALYSIS** 9.a. The plating facility proposed in ADP application CL- 1650 will emit TAPs. The TAP emissions associated with this permitting action have been quantified as follows:



### 9.1 Facilitywide Toxic Air P**ollutant Emission Summary** Toxic Compound CAS # Total Annual Emissions (lb/yr) Small

Quantity Emission Rate (lb/yr) Am

bient Impact (μg/m3 ) Acceptable

Source Impact Level (μg/m3 ) TAP

Class EPA Classified HAP (Yes/No) Hexavalent Chromium 7440 -47 - 3 0.0083 ---- 0.00002 0.000083 (Annual) A Yes Nickel and Compounds 7440 -02 -0 3.25 0.5 0.0021 0.0021 (Annual) A Yes Copper Mist 7440 - 50 - 8 96 175 -- 3.3 (24 -hour) B No Zinc Chloride 7646 - 85 -7 135 175 -- 3.3 (24 -hour) B No Cyanide 51 - 12 - 5 5.6 1750 -- 17 (24 -hour) B No Hydrochloric Acid 7647 -01 -0 110 175 -- 7.0 (24 -hour) B Yes Methanol 67 - 56 -7 333 43,746 -- 870 (24 -hour) B Yes All increases in individual toxic air pollutant emissions were below the small quantity emission rates (SQER) identified in WAC 173 -460 with the exception of hexavalent chromium and nickel.Technical Support Document ADP Application CL - 1650 Pacific Northwest Plating, Inc. ADP 02 -2442R1

7 9.b Emissions were modeled using EPA's TSCREEN version 95250 model. The results of the model indicate that the project will not cause an incremental increase in ambient concentrations of hexavalent chromium nor nickel greater than the acceptable source impact levels identified in WAC 173 -460. The results of this modeling are shown in Table 9.1. **Conclusions** 9.c Relocation of the electroplating facility and installation of additional equipment, as proposed in ADP Application CL - 1650, will not cause the ambient air quality requirements of Title 40 Code of Federal Regul ations (CFR) Part 50 "National Primary and Secondary Ambient Air Quality Standards" to be violated. 9.d Relocation of the electroplating facility and installation of additional equipment, as proposed in ADP Application CL - 1650, will not cause the requirements of WAC 173 -460 "Controls for New Sources of Toxic Air Pollutants," WAC 173 -470 "Ambient Air Quality Standards for Particulate Matter," WAC 173 -474 "Ambient Air Quality Standards for Sulfur Oxides," and WAC 173 -475 "Ambient Air Quality Standards for Ca rbon Monoxide, Ozone, and Nitrogen Dioxide" to be violated. 9.e Relocation of the electroplating facility and installation of additional equipment, as proposed in ADP Application CL - 1650, can be operated without causing a violation of emission standards f or sources as established under SWCAA General Regulations Sections 400 -040 "General Standards for Maximum Emissions," 400 -050 "Emission Standards for Combustion and Incineration Units," and 400 -060 "Emission Standards for General Process Units." **10. DISC USSION OF APPROVAL CONDITIONS**  SWCAA has made a determination to issue ADP 02 -2442R1 in response to ADP Application CL - 1650. ADP 02 -2442R1 contains approval requirements deemed necessary to assure compliance with applicable regulations and emission standards as discussed below. 10.a Supersession of Previous Permits. ADP 02 -2442R1 supersedes ADP 02 -2442 in its entirety. 10.b Emission Limits for Electroplating Operations. SWCAA 02 -2442R1 establishes the following emission limits for the facility: Pollutant Emission Rate Emissions Hexavalent Chromium 0.033 lb per million amp -hour 0.033 lb/yr Nickel 2.88 lb per million amp -hour 3.25 lb/yr Copper 66 lb per million amp -hour 96 lb/yr Cyanide 3.86 lb per million amp -hour 5.6 lb/yr Zinc 90 lb per million amp -hour 135 lb/yr Methanol 0.061 lb/hr 333 lb/yr Hydrochloric Acid 0.025 lb/hr 110 lb/yr 10.c Operating Limits and Requirements: The surface tension of chrome plating tank shall not exceed 45 dynes per centimeter. The nickel plating tanks shall operate with a foam blanket of at least 1” in thickness. The hydrochloric acid tank shall not be heated and shall be covered when not in use. 10.d Monitoring and Recordkeeping Requirements: Sufficient monitoring reporting and recordkeeping was establi shed to document compliance with the established emission limits and provide for general requirements (e.g. upset reporting, annual emission inventory submission). Recordkeeping and monitoring were also established to demonstrate compliance with Title 40 Code of Federal Regulations (CFR) 63.340 et seq. (Subpart N) "National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks." However, the frequency of monitoring required by 40CFR63.340 i s based onTechnical Support Document ADP Application CL - 1650 Pacific Northwest Plating, Inc. ADP 02 -2442R1

8 hours of plating activity. PNW Plating currently does not have hours meters on its plating tanks. Therefore a very conservative amp -hrs frequency was included in the Permit to make compliance demonstration simpler. 10.e Reporting: The information necessary to calculate annual emissions (Amp -hours), and the annual emissions inventory itself is required to be submitted to SWCAA each year by March 15 th . This information will be used to assess the compliance status of the source and develop a general emission inventory. In addition, upset conditions with the potential to cause excess emissions must be reported promptly, consistent with SWCAA 400 - 107. **11. START -** **UP AND SHUTDOWN/ALTERNATIVE OPERATING SCENARIOS/POLLUTION PREVENTION** 11.a Start-up and Shutdown Provisions. Pursuant to SWCAA 400 -081 "Start-up and Shutdown", technology based emission standards and control technology determinations shall take into consideration the physical and operational ability of a source to comply with the applicable standards during start-up or shutdown. Where it is determined that a source is not capable of achieving continuous compliance with an emission standard during start-up or shutdown, SWCAA shall include appropriate emission limitations, operating parameters, or other criteria to regulate performance of the source during start-up or shutdown. The foam blanket on the nickel plating tanks requires plating activity to generate. Therefore when nickel plating is started after prolonged periods of shutdown, the foam blanket is not yet generated. The emission limits established by the permit do not apply during the first 30 minutes after startup each day. 11.b Alternate Operating Scenarios. SWCAA conducted a review of alternate operating scenarios applicable to equipment affected by this permitting action. The permittee did not propose or identify any applicable alternate operating scenarios. Therefore, none were included in the approval conditions. 11.c Pollution Prevention Measures. SWCAA conducted a revi ew of possible pollution prevention measures for the facility. No pollution prevention measures were identified by either the permittee or SWCAA separate or in addition to those measures required under BACT considerations. This facility proposes to operate with zero process wastewater discharge and minimized the amounts of dangerous wastes generated. **12. EMISSION MONITORING AND TESTING** 12.a Testing Requirements. Emissions from the electroplating facility are too small to warrant periodic testing as a permit requirement. This facility is com plying with the fume suppressant surface tension limit in 40 CFR 63.340 et seq. (Subpart N) "National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks." Therefore testing is not required by this subpart. **13. FACILITY HISTORY** 13.a General History. This facility began operation at its original location in 2002. The original facility was located at 7000 NE 40th Avenue, Suite A- 1, Vancouver, WA. 13.a Previous Permitting Actions. SWCAA has previously issued the following Permits for Pacific NW Plating, Inc. 's facility in Vancouver: Permit Application Date Issued Description 02 -2442 CL - 1506 2 -24 -02 Installation of a new metal finishing facility which will include electroplating of chromium, copper and nickel at 7000 NE 40th Avenue, Suite A- 1, Vancouver, WA. **14. PUBLIC NOTICE/COMMENT** 14.a Public Notice for ADP Application CL- 1650. No comments were received for this permitting action.