### November 16, 2010

Mr. Keith Henderson American Plating 504 NE 2 nd 

### 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 , 20 10 . 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 define d 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 1 14

. Sincerely,
Natalia Kreitzer Air Quality

Engineer

Enclosure

# COMPLIANCE EVALUATION REPORT ON

- SITE INSPECTION
Date of Inspection: November 10 , 20 10 Date of Report: November 16 , 20 10 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 2 nd 

### Street Winlock, WA 98596 Telephone: 360

- 736

- 0052 Fax: 360

- 736

- 0105 Seattle Work: 206

- 762

- 6717 Source Contact(s): Keith Henderson, VP In spection 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 2 0 , 200 9 by CCR Safety Equip.: None required. Eye glasses, safety shoes suggested Emission Inv. Y ear: 200 9 Emission Units: 3 200 9 Annual Emissions Potential to Emit (PTE) Criteria Emissions: VOC

- 0.00 tpy 1.0 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 t py SO 2 

### - 0.00 tpy 0.00 tpy TAP Emissions:

- 0.0 1 tpy 0.21 tpy HAP Emissions:

- 0.0 0 tpy <0.01 tpy
**A. Process**  **Description:** American Plating is a metal finishing facility which include s 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 o f 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 ft2 

### and a production capacity

o f 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 ft2 

### and a production capacity o f 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 ft2 

### and a production capacity o f 1,000 Amps. One non-resettable Amp

-hour meter is located on the copper acid electroplating tank. All equipment from this facility exhaust s 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 p erforms 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 dy ne test on the chrome tank was taken on November 1, 2010

. Mr. Henderson is now performing his dy ne 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 3 1, 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 , 20 10 and included amp/hrs and emissions for the facility

. All records for the facility are kept onsite. S urface tension, foam thickness, amp -hour reading and fume suppressant additions are all kept on a clipboard in the plating room. M SDSs are stored in the office. A detaile d description of the records review is found in Appendix II.
**E. Annual Emissions:**  Hexavalent Chromium: 0.00134 1 

### lb mi llion Am

p hr

 

### x 66,028 Amp

-hr = 0.0000 9 lb 

### yr Nickel: 0.25 1 

### lb mi llion Am

p hr

 

### x 1 33,560 Amp

-hr = 0.0 3 3 lb 

### yr Copper: 66 lb mi llion Am

p hr

 

### x 2 31,198 2 

### Amp

-hr = 1 5.26 lb 

### yr Cyanide: 3.86 lb mi llion Am

p hr

 

### x 17,211 Amp

-hr = 0.0 66 lb 

### yr 1 July 31, 2006 Source Tes t 2 Combined Amp

- hrs for copper acid and copper cyanide plating 

### The facility

P otential 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 i s 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 Approve d metal finishing facility which will include electroplating of chromium, copper, and nickel

### A**PPENDIX 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 Documen t for this Air Discharge Permit. 200 9 Emissions 0.0000 9 lb/yr 0.0 3 3 lb/yr 1 5

. 3 lb/yr 0.0 7 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 exc eed zero percent opacity for more than 3 minutes in any one hour period as determined by a Certified Observer certified in accordance w

ith SWCAA Method 9 (See Appendix A of SWCAA 400). No visible emissions observed during inspection

**2.2 Operating Lim its**  **and Requirem ents**  **No. Operating**  **Limits and Requirem** **ents 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. 0.0 6 million amp

-hour for 200 9 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 amp hour level. 0. 1 3 million amp

-hour for 200 9

9. Copper plating operation shall not exceed 6.24 m illion amp

-hour/year. 0. 2 3 million amp

-hour for 200 9 ( copper cyanide and copper acid combined) 10. The plating solution liquid level shall be maintained at least 6" below t he 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. D oors 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 Requirem** **ents Inspector’s Observation** 

13. Ampere

-hour accumulators must be operating properly whenever elect rical 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. S WCAA 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 Moni toring and Record Keeping Requirem** **ents No.**  **Monitoring and Record Keeping Requirem** **ents 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 retur n 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 we ek 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 re cord entry

. I f 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 Requirem ents**  **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 Requirem** **ents No.**  **Tuning and Testing Requirem ents**  **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 Requirem ents**  **No. Reporting Requirem** **ents Inspector’s Observation**  27. The permittee shall notify SWCAA in writing within ten (10) days after completing initial installation of new equipment. T his will allo w 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 S WCAA annually by March 15 th (b) Summary of emissions Shall be reported to SWCAA annually by March 15 th

. 2009 report received March 3 , 2010**No. 40 CFR 63 Subpart N NESHAP Requirem** **ents 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 reco rdkeeping. A p hone report shall be submitted within two wo rking days after periods of malfunction that are inconsistent with the operations and maintenance plan with a follow up letter within seven wo rking 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 inc orporated 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 Requirem** **ent s**  **Inspector’s Observation**63.11507(

a) If you ow

n 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 i s 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 ow

n 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 poli sh 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 t he 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, ba

rrels 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, pre cleaning 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, 200863.11509(

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. I f a deviation has occurred during the year, each annual compliance report m

ust 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.

### An **nual 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 s ubpart WWWWWW , National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations as follows: The applicable managemen t 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 pres ented herein is correct to the best of my knowledge.

__________________________________ _______________________________

(Signature) (Date)

__________________________________ (

____ )

_______________________

(Name/title) (Telephone No.)