November 16, 2010

Mr. Keith Henderson

American Plating

504 NE 2nd Street

Winlock, WA 98596

Dear Mr. Henderson:

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 November 10, 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 114.

Sincerely,

Natalia Kreitzer

Air Quality Engineer

Enclosure
COMPLIANCE EVALUATION REPORT

ON-SITE INSPECTION

Date of Inspection: November 10, 2010 Date of Report: November 16, 2010

Source Name: American Plating Inc. (formerly Specialty Stainless and Aluminum)

SWCAA ID. No.: 2113

Physical Location: 524 North Gold Centralia, WA 98531

Mailing Address: 504 NE 2nd Street Winlock, WA 98596

Telephone: 360-736-0052

Fax: 360-736-0105

Seattle Work: 206-762-6717

Source Contact(s): Keith Henderson, VP

Inspection Contact: Keith Henderson, VP

AIRS No.: NA Title V No; Opt-Out No

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

Permits: 01-2354

SWCAA Rep: Natalia Kreitzer

Previous Inspection: November 20, 2009 by CCR

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

Emission Inv. Year: 2009

Emission Units: 3

2009 Annual Emissions Potential to Emit (PTE)

Criteria Emissions: VOC - 0.00 tpy 1.0 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: - 0.01 tpy 0.21 tpy

HAP Emissions: - 0.00 tpy <0.01 tpy

A. Process Description: American Plating is a metal finishing facility which includes electroplating of 

chromium, copper, and nickel. This facility performs decorative chromium electroplating based on the 

thickness of the chromium layer electrodeposited and is subject to 40 CFR 63.340 et seq. (Subpart N) 

"National Emission Standards for Chromium Emissions from Hard and Decorative Chromium 

Electroplating and Chromium Anodizing Tanks." The facility is also subject to 40 CFR 63.11504 et seq. 

(Subpart WWWWWW) “National Emission standards for Hazardous Air Pollutants: Area Source 
Standards for Plating and Polishing Operations”. Air Discharge Permit SWCAA 01-2354 was the 

first air regulatory permit for this facility. 

B. Emission Units/Control Equipment Descriptions:

1. Chrome Plating. One chromic acid electroplating tank with a total surface area of 12 

square feet (ft2) and a production capacity of 2,000 Amps. Emissions from the chromic 

acid tank are controlled with the use of Fumetrol #140 mist suppressant which operates by

reducing the surface tension of the bath. One non-resettable Amp-hour meter is located on 

the chromic acid tank.

2. Nickel Plating. One nickel electroplating tank with a surface area of 12 ft2and a 

production capacity of 2,000 Amps. Emissions from the nickel electroplating tank are

controlled with the use of a wetting agent, Coventya Criterion Air Wetter, which reduces 

surface tension and creates a foam blanket on the tank. A non-resettable Amp-hour meter is

located on the nickel electroplating tank. 

3. Copper Plating:

a. Copper Cyanide Electroplating Tank. One copper cyanide electroplating tank with a 

total surface area of 12 ft2and a production capacity of 1,000 Amps. One nonresettable Amp-hour meter is located on the copper cyanide electroplating tank.

b. Copper Acid Electroplating Tank. One copper acid electroplating tank with a total 

surface area of 12 ft2and a production capacity of 1,000 Amps. One non-resettable 

Amp-hour meter is located on the copper acid electroplating tank.

All equipment from this facility exhausts via one general room exhaust at 1370 acfm and 81 oF 

through a stack 28 feet above ground level and 12 inches in diameter.

C. Observations During Inspection 

American Plating mainly performs decorative plating 

of custom automobile parts. The following meter 

readings were observed during the inspection:

Amp-Hrs Hours

Tank Current Previous Current Previous

Chrome 222,649 168,772 625 516.5

Copper 

Cyanide

84,649 70,655 --- ---

Copper Acid 1,032,925 822,500 --- ---

Nickel 566,654 438,619 --- ---

Electroclean 145,206 --- --- ---

Soap 84,099 --- ---

No open containers were observed during the inspection. The last dyne test on the chrome tank 

was taken on November 1, 2010. Mr. Henderson is now performing his dyne testing in-house 

rather than sending sample off to a lab. Mr. Henderson is taking samples every 40 hours as 

required by the Permit and the NSPS.

An initial source test was performed on July 31, 2006. Results indicate that nickel and 

hexavalent chrome emissions are well below permit limits.
D. Reporting/Records Review:

The annual report was received on March 3, 2010 and included amp/hrs and emissions for the 

facility. All records for the facility are kept onsite. Surface tension, foam thickness, amp-hour 

reading and fume suppressant additions are all kept on a clipboard in the plating room. MSDSs 

are stored in the office. A detailed description of the records review is found in Appendix II.

E. Annual Emissions:

Hexavalent Chromium: 0.001341

lb

million Amp  hr

x 66,028Amp-hr = 0.00009

lb

yr

Nickel: 0.251

lb

million Amp  hr

x 133,560 Amp-hr = 0.033

lb

yr

Copper: 66 

lb

million Amp  hr

x 231,1982 Amp-hr = 15.26

lb

yr

Cyanide: 3.86 

lb

million Amp  hr

x 17,211 Amp-hr = 0.066

lb

yr

1 July 31, 2006 Source Test

2 Combined Amp-hrs for copper acid and copper cyanide plating

The facility Potential to Emit (PTE) for TAPs and HAPs is set by the emission limits in Air 

Discharge Permit 01-2354. The VOC emissions for the facility will be limited by the process use 

of solvent containing cleaners. At this time, the estimated use of cleaning solvent will not exceed

1.0 tpy. The facility PTEs are given on the first page of this report.

F Compliance Assessment with Applicable Requirements/Emission Limits: 

See Appendix II of this document.

G. Compliance Summary:

American Plating Inc. is subject to 40 CFR 63 Subpart N: Chromium Electroplating NESHAP 

compliance requirements and 40 CFR 63.11504 et seq. (Subpart WWWWWW) “National Emission 

standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations”. 

No violations of any provisions of SWCAA 400, NESHAP standards or applicable Air Discharge 

permits were observed during inspection of the American Plating facility. This facility is not 

subject to any other NSPS, MACT, or NESHAP.

H. Appendices and Attachments: 

I Regulatory Permit Summary

II Compliance Assessment
APPENDIX I

Regulatory Permit Summary

ADP Number Application Date Issued Description

01-2354 L-475 August 13, 2003 Approved metal finishing facility which will 

include electroplating of chromium, copper, 

and nickel
APPENDIX II

Compliance Summary

All Requirements Contained in Air Discharge Permit 01-2354

No. Emission Limits Inspector’s Observation

1. Combined emissions from plant operations shall not exceed:

Pollutant Emission Limit

Hexavalent Chromium 0.21 lb/yr

Nickel 5.4 lb/yr

Copper 412 lb/yr

Cyanide 12 lb/yr

Emissions shall be calculated based on the methodology outlined in Section 6 

of the Technical Support Document for this Air Discharge Permit.

2009 Emissions

0.00009 lb/yr

0.033 lb/yr

15.3 lb/yr

0.07 lb/yr

2. Emissions of toxic air pollutants shall not individually exceed the SQER 

provided in WAC 173-460 except those listed in condition 1 above.

TAPs < SQER

3. Emissions to the atmosphere which cause or contribute to a nuisance odor 

shall use recognized good practice and procedures to reduce these odors to a 

reasonable minimum.

No odor observed during 

inspection

4. Visible emissions shall not exceed zero percent opacity for more than 3 

minutes in any one hour period as determined by a Certified Observer 

certified in accordance with SWCAA Method 9 (See Appendix A of SWCAA 

400).

No visible emissions

observed during 

inspection

2.2 Operating Limits and Requirements

No. Operating Limits and Requirements Inspector’s Observation

5. The surface tension of the chrome plating tank shall not exceed 45 dynes per 

centimeter.

37.96 based on 

November 1, 2010

sampling

6. The foam blanket on the nickel tank shall not be less than 1” during plating 

operations.

~1 inch during inspection

7. Chrome plating operation shall not exceed 6.24 million amp-hour/year. 0.06 million amp-hour 

for 2009

8. Nickel plating operation shall not exceed 1.87 million amp-hour/year unless 

source testing is performed and demonstrates that compliance with the nickel 

emission limit in 1. above can be met at a higher annual nickel plating amphour level.

0.13 million amp-hour 

for 2009

9. Copper plating operation shall not exceed 6.24 million amp-hour/year. 0.23 million amp-hour 

for 2009 (copper cyanide 

and copper acid 

combined)

10. The plating solution liquid level shall be maintained at least 6" below the top 

of the tank.

Liquid levels at least 6” 

below tank top during 

inspection

11. The building exhaust must be no less than 28 feet above ground level. No indication exhaust 

below 28 feet

12. Open doors shall be prohibited during plating operations except to move 

equipment/materials into or out of the building. Doors shall be closed 

immediately after equipment/materials are transferred into/out of the building.

One small door was open 

during the inspection. 

Mr. Henderson was 

reminded that doors must 

remain closed
No. Operating Limits and Requirements Inspector’s Observation

13. Ampere-hour accumulators must be operating properly whenever electrical 

current is applied to tank with one accumulator located on the chromium tank, 

one accumulator on the nickel tank, one accumulator located on both copper 

tanks and one accumulator located on the gold tank.

Amp-hour meters 

installed and operational

14. VOC containing products shall be collected and stored in closed containers. No open containers 

observed during 

inspection

15. Operations that cause or contribute to a nuisance odor shall use recognized 

good practice and procedures to reduce these odors to a reasonable 

minimum.

No odors observed 

during inspection

16. Emission units identified in ADP 01-2354 shall be maintained and operated 

in total and continuous conformity with the emission levels and operational 

requirements specified in this ADP. SWCAA reserves the right to take any 

and all appropriate action to maintain the conditions of this ADP, including 

directing the facility to cease operations until corrective action can be 

completed.

No indication facility not 

operating as required

2.3 Monitoring and Record Keeping Requirements

No. Monitoring and Record Keeping Requirements Inspector’s Observation

17. The surface tension of the chromium plating tank shall be recorded 

in an O/M log according to the following schedule:

(a) Initially record every 4 hours of tank operation for 10 

consecutive readings

(b) If no violations occur, record every 8 hours of operation 

for 5 consecutive readings

(c) If no violations occur, record every 40 hours of 

operation

(d) If a violation occurs, the monitoring schedule must 

return to the frequency in 16.a for the specified time.

Surface tension tests taken as 

required. The facility is currently 

sampling monthly which is less than 

40 hours of plating time. Sampling 

was performed November 1, 2010. 

No dyne violations have occurred.

18. Foam thickness on the nickel plating tank shall be recorded once 

per week no sooner than 30 minutes after start of nickel plating 

operations.

Recorded on clipboard every Monday

19. Ampere-hour accumulator readings, calibration, and servicing 

shall be recorded in the O/M log monthly; each entry shall contain 

date and name for each entry.

Recorded on clipboard every Monday

20. Fume suppressant use shall be recorded in the O/M log for each 

addition and shall include quantity and time of addition.

Recorded for each addition

21. Purchase receipts and MSDSs for all consumable products shall be 

retained on site for inspection by SWCAA.

Kept in main office

22. Each record required by this ADP shall include the date and the 

name of the person making the record entry. If a control device 

or process is not operating during a specific time period, a record 

shall be made to that effect.

All records kept by Mr. Henderson

23. All records required by this ADP shall be kept on site for a 

minimum period of no less than five years and shall be available 

for inspection by SWCAA representatives.

Records since beginning operation 

onsite
No. Monitoring and Record Keeping Requirements Inspector’s Observation

24. All upset conditions and/or excess emissions shall be recorded for 

each occurrence.

No upsets reported

2.4 Tuning and Testing Requirements

No. Tuning and Testing Requirements Inspector’s Observation

25. Hexavalent chromium plating operations shall be emission tested 

within 120 days of initial operation in accordance with Appendix A 

of ADP SWCAA 01-2354.

Initial test performed July 31, 2006. 

No subsequent testing required

26. Nickel plating operations shall be emission tested prior to 

exceeding 1.87 million Amp-hours of operation per year in 

accordance with Appendix A of ADP SWCAA 01-2354.

Initial test performed July 31, 2006. 

No subsequent testing required

2.5 Reporting Requirements

No. Reporting Requirements Inspector’s Observation

27. The permittee shall notify SWCAA in writing within ten (10) days 

after completing initial installation of new equipment. This will 

allow proper inspections and observations to be conducted for the 

new equipment. 

Mr. Henderson contacted SWCAA via 

telephone

28. Upset conditions shall be reported to SWCAA as soon as possible in 

accordance with SWCAA 400-107.

No upsets reported

29. Operations of the electroplating facility shall be reported

Reported as follows

(a)Amp-hours of each meter shall be reported to SWCAA 

annually by March 15th

(b) Summary of emissions Shall be reported to SWCAA 

annually by March 15th.

2009 report received March 3, 2010
No. 40 CFR 63 Subpart N NESHAP Requirements Inspector’s Observation

63.342

(d)(2)

If using a wetting agent, not to allow the surface tension of 

the electroplating tank to exceed 45 dynes per centimeter 

(dynes/cm)

Dynes tests records indicate no 

violation. Last test results were 

37.96 dynes.

63.342

(f)(3)

Work practice standards: Operations and maintenance plan 

requirements.

O and M procedures were 

incorporated into the SWCAA Air 

Discharge Permit.

63.342

(f)(3)(iii)

Work practice standards recordkeeping. A phone report 

shall be submitted within 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.

No malfunctions reported

63.343

(b)

Demonstration of initial compliance Exempted because this is decorative 

chrome using a wetting agent to 

inhibit chromium emissions. 

However, facility must comply with 

63.343(c)(5)(ii).

63.343

(c)(5)(ii)

Surface tension of chromium plating tank shall monitored 

according to the following schedule:

(e) Initially record every 4 hours of tank operation for 

10 consecutive readings

(f) If no violations occur, record every 8 hours of 

operation for 5 consecutive readings

(g) If no violations occur, record every 40 hours of 

operation

If a violation occurs, the monitoring schedule must return to 

the frequency in 19.a for the specified time.

Surface tension tests taken as 

required. The facility is currently 

sampling monthly which is less than 

40 hours of plating time. Sampling 

was performed November 1, 2010. 

No dyne violations have occurred.

63.346

(a)

Owner or operator shall fulfill all recordkeeping 

requirements of Subpart N with regards to maintenance, 

malfunctions and actions taken, and suppressant addition.

OK, requirements incorporated into 

Air Discharge Permit

63.347

(c)(2)

Initial notifications of construction and start-up. Mr. Henderson contacted SWCAA 

via telephone

63.347

(h)

Ongoing compliance status reports for area sources shall be 

completed yearly in accordance with this section. The report 

shall be maintained on site and available for inspection upon 

request.

OK all required information 

incorporated into Air Discharge 

Permit requirements and maintained 

in logs on site.

No. 40 CFR 63 Subpart WWWWW NESHAP Requirements Inspector’s Observation
63.11507(

a)

If you own or operate an affected new or existing noncyanide electroplating tank that operates at a pH of less than 

12, comply with (a)(1), (2) or (3) and (g):

(1) You must use a wetting agent/fume suppressant; 

you must initially add the wetting agent/fume 

suppressant in the amounts recommended by the 

manufacturer; you must add wetting agent/fume 

suppressant in proportion to the other bath 

chemistry ingredients that are added to replenish the 

tank baths as in the original make-up

(2) You must capture and exhaust emissions to a 

composite mesh pad, packed bed scrubber or mesh 

pad mist eliminator

(3) You must cover the tank surface at least 95% of the 

electrolytic process operating time

This applies to the nickel tanks since 

nickel is a metal HAP. American 

Plating is using Coventya Maxima 

Premier plating solution. According 

to Coventya,, Maxima Premier 

comes pre-mixed with a wetting 

agent/fume suppressant that meets 

the requirements of this rule. In 

addition, American Plating adds 

Criterion Air Wetter to further 

reduce the surface tension of the 

bath. Keith adds this when the foam 

layer visibly starts to decrease. 

63.11507(

e)

If you own or operate an affected new or existing dry 

mechanical polishing equipment that emits one or more of the 

metal HAPs you must operate a capture system that captures 

PM and transports the emissions to a cartridge, fabric or 

HEPA filter and 

(1) You must operate all capture and control devices 

according to the manufacturer’s specifications and 

operating instructions

(2) 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

This does not apply to the facility. Per

Keith, the facility does not polish 

finished products.
63.11507(

g)

If you operate an affected polishing process unit you must:

(1) Minimize bath agitation when removing any parts 

processed in the tank as practicable

(2) Maximize the draining of bath solution back into the 

tank, as practicable by extending drip time when 

removing parts from the tank; using drain boards or 

withdrawing parts slowly from the tank

(3) Optimize the design of barrels, racks and parts to 

minimize dragout of bath solution (such as by using 

slotted barrels and tilted racks or by designing parts 

with flow-through holes to allow the tank solution to 

drip back into the tank)

(4) Use tank covers whenever practicable

(5) Minimize or reduce heating of process tanks

(6) Perform regular repair, maintenance and preventative 

maintenance of racks, barrels and other equipment

(7) Minimize bath contamination, such as through the 

prevention or quick recovery of dropped parts, use of 

distilled/de-ionized water, water filtration, precleaning of parts to be plated and through rinsing of 

pre-treated parts to be plated

(8) Maintain quality control of chemicals, and chemicals 

and or other bath ingredient concentrations in the 

tanks

(9) Perform general good housekeeping, such as regular 

sweeping or vacuuming and periodic washdowns

(10) Minimize spills and overflow of tanks

(11) Use squeegee rolls in continuous or reel-to reel 

plating tanks

(12) Perform regular inspections to identify leaks and 

other opportunities for pollution prevention.

The facility performs general 

management practices such as hanging 

parts over tanks to drip back into the 

tanks, covering tanks at night, visually 

inspection tanks and other equipment, 

filtering bath contents to reduce 

contaminants, vacuuming monthly, 

etc.

63.11509(

a)(3)

The Initial Notification must be submitted no later than 120 

calendar days after July 1, 2008

SWCAA received copy of notification 

on October 29, 2008
63.11509(

c)

You must prepare an annual certification of compliance 

report

(1) You must state in your annual compliance 

certification that you have added wetting 

agent/fume suppressant to the bath according to the 

manufacturer’s specifications and instructions

(2) You must state in your annual certification that you 

have operated and maintained the control system 

according to the manufacturer’s specifications and 

instructions

(3) You must state in your annual compliance 

certification that you have implemented the 

applicable management practices as practicable

(4) Each annual compliance report must be prepared no 

later than January 31 of the year immediately 

following the reporting period and kept in a readily

accessible location for inspector review. If a 

deviation has occurred during the year, each annual 

compliance report must be submitted along with the 

deviation report postmarked or delivered no later 

than January 31.

The compliance date for this 

regulation is July 1, 2010. Therefore 

the first annual certification of 

compliance must be completed by 

January 31, 2011.
Annual Compliance Certification

(To be completed no later than January 31 for the previous calendar year)

This facility IS operating 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 as follows:

The applicable management practices identified in 63.11507(g) have been implemented, as 

practicable;

The wetting agent/fume suppressant has been added to the nickel baths according to 

manufacturer’s specifications and instructions; and

I hereby certify that the information presented herein is correct to the best of my knowledge.

__________________________________ _______________________________

 (Signature) (Date)

__________________________________ (____)_______________________

 (Name/title) (Telephone No.)