TECHNICAL SUPPORT DOCUMENT

Order of Approval SWCAA 01-2354

Specialty Stainless & Aluminum, Inc.

NOC Application L-475

Final Date: August 13, 2003

Prepared By: Natalia Kreitzer

Air Quality Engineer

Southwest Clean Air Agency
SWCAA 01-2254

TABLE OF CONTENTS

Section Page

1. Facility Identification 1

2. Facility Description 1

3. Current Permitting Action 1

4. Process Description 1

5. Equipment/Activity Identification 1

6. Emissions Determination 2

7. Regulations and Emission Standards 3

8. RACT/BACT/BART/LAER/PSD Determinations 5

9. Ambient Impact Analysis 5

10. Discussion of Approval Conditions 6

11. Start-up and Shutdown Provisions/Alternative Operating Scenarios/Pollution 

Prevention

7

12. Tuning and Testing 7

13. Facility History 7

14. Public Comment 7
SWCAA 01-2254

Abbreviations

AP-42 Compilation of Emission Factors, AP-42, Fifth Edition, Volume 1, Stationary Point and 

Area Sources – published by the US Environmental Protection Agency

BACT Best available control technology

CFR Code of Federal Regulations

EPA U.S. Environmental Protection Agency

H2SO4 Sulfuric acid

HAP Hazardous air pollutant listed pursuant to Section 112 of the Federal Clean Air Act

HCl Hydrochloric acid

MSDS Material Safety Data Sheet

NOC Notice of Construction application

NOV Notice of Violation

PSD Prevention of Significant Deterioration

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 Code
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Specialty Stainless & Aluminum, Inc. SWCAA 01-2354

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1. FACILITY IDENTIFICATION

Applicant Name: Specialty Stainless & Aluminum, Inc.

Applicant Address: 524 N Gold Street, Centralia, WA 98531

Facility Name: Same as above

Facility Address: Same as above

SWCAA Identification: 2113

Contact person: Keith Henderson

Primary Process: Electroplating

SIC/NAICS Code: 3471/ 332813

Facility Classification: Natural Minor

2. FACILITY DESCRIPTION

Specialty Stainless & Aluminum, Inc. (Specialty Stainless) is a new metal finishing facility which will include 

electroplating of chromium, copper and nickel. 

3. CURRENT PERMITTING ACTION

This permitting action is in response to Notice of Construction application number L-475 (NOC L-475) dated December 

12, 2000. This is a new facility which has not been previously approved.

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. 

The facility consists of the following tanks:

1. One chromic acid electroplating tank with a total surface area of 12 square feet (ft2), a maximum volume of 718 

gallons, and a production capacity of 2,000 Amps 

2. One nickel electroplating tank with a total surface area of 12 ft2, a maximum volume of 718 gallons, and a 

production capacity of 2,000 Amps

3. One copper acid electroplating tank with a total surface area of 12 ft2, a maximum volume of 957 gallons, and a 

production capacity of 1,000 Amps 

4. One copper cyanide electroplating tank with a total surface area of 12 ft2, a maximum volume of 957 gallons, and 

a production capacity of 1,000 Amps

5. One gold electroplating tank with a total surface area of 6 ft2, a maximum volume of 89 gallons, and a production 

capacity of 25 Amps

6. One soap cleaner tank with a maximum volume of 718 gallons and a capacity of 1,000 Amps

7. One electroclean tank with a maximum volume of 718 gallons

8. One 10% sulfuric acid (H2SO4) tank with a maximum volume of 718 gallons

9. One 10% hydrochloric acid (HCl) tank with a maximum volume of 718 gallons and one HCl tank with a volume 

of 89 gallons

10. 20 rinse tanks with a maximum volume of 718 gallons each and seven rinse tanks with a volume of 89 gallons 

each.

5. EQUIPMENT/ACTIVITY IDENTIFICATION

5.a Chromic Acid Electroplating Tank. 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 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 will be located on the chromic acid tank.
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5.b Nickel Electroplating Tank. One nickel electroplating tank with a surface area of 12 ft2and a production capacity 

of 2,000 Amps. Emissions from the nickel electroplating tank will be controlled with the use of a wetting agent, 

Rohco Wetter, which reduces surface tension and creates a foam blanket on the tank. A non-resettable Amp-hour 

meter will be located on the nickel electroplating tank. 

5.c Copper Cyanide Electroplating Tank. One copper cyanide electroplating tank with a total surface area of 12 ft2

and a production capacity of 1,000 Amps. One non-resettable Amp-hour meter will be located on the copper 

cyanide electroplating tank.

5.d 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 will be located on the copper acid 

electroplating tank.

5.e Gold Electroplating Tank. One gold electroplating tank with a total surface area of 6 ft2and a production capacity 

of 25 Amps. One non-resettable Amp-hour meter will be located on the gold electroplating tank.

6. EMISSIONS DETERMINATION

Hexavalent chromium emissions from the facility were estimated at 0.21 pounds per year based on 6.24 million 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

million Amp  hr

x 6.24 million Amp - hr 

yr

= 0.21 

lb

yr

Nickel emissions from the facility were estimated at 5.4 pounds per year based on 1.87 million amp-hours, an emission factor 

of 2.88 pounds per million amp-hours 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

million Amp  hr

x 1.87 million Amp - hr 

yr

x = 5.4

lb

yr

Copper emissions from the facility were estimated at 412 pounds per year based on 6.24 million amp-hours and an emission 

factor of 1.1 pounds per million amp-hours 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 from 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

million Amp  hr

x 6.24 million Amp - hr 

yr

x = 412 

lb

yr

Cyanide emissions from the facility were estimated at 12 pounds per year based on 3.12 million amp-hours and an emission 

factor of 1.1 pounds per million amp-hours from EPA’s AP-42 section 12.20 “Electroplating” (7/96) for uncontrolled copper 

electroplating. AP-42 only provides an emission factor for a 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:
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3.86 

lb

million Amp  hr

x 3.12 million Amp - hr 

yr

x = 12.0 

lb

yr

Gold emissions from the facility were estimated at 7 pounds per year based on 0.078 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

million Amp  hr

x 0.078 million Amp - hr 

yr

x = 7.0 

lb

yr

Emissions of sulfuric acid from the facility were estimated to be negligible from the 10 percent by weight sulfuric acid tank

based on the following equation from the State of Washington and Ajay Kumar, P.E., “Estimating Emission Rated from

Haz Mat Releases,” Pollution Engineering, February 2000: Q = 5.10x10-6* U

0.78 * Pv * Mw0.67 * Ap0.94 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 7x10-21 pounds per year.

Emissions of hydrochloric acid from the facility were estimated to be negligible from the 10 percent by weight hydrochloric 

acid tank based on the following equation from the State of Washington and Ajay Kumar, P.E., “Estimating Emission Rated 

from Haz Mat Releases,” Pollution Engineering, February 2000: Q = 5.10x10-6* U

0.78 * Pv * Mw0.67 * Ap0.94 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 0.65 pounds per year.

Actual annual emissions shall be calculated for hexavalent chromium, nickel, copper, cyanide and gold using the above 

emission factors (unless source testing is performed, in which case the source test result in pounds per million Amp-hours 

shall be the emission factor used) and actual Amp-hours per year.

7. REGULATIONS 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 (40 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 the 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 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"

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 based on the thickness of the chromium layer electrodeposited and the Amperes per 

square meter and is subject to this regulation. Decorative 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.c 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.
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7.d RCW 70.94.152 provides for the inclusion of conditions of operation as are reasonably necessary to assure the 

maintenance of compliance with the applicable ordinances, resolutions, rules and regulations when issuing an Order 

of Approval for installation and establishment of an air contaminant source.

7.e WAC 173-401 "Operating 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.

7.f 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.g WAC 173-470 "Ambient Air Quality Standards for Particulate Matter" establishes ambient air quality standards 

for total suspended particulate matter and for particulate matter smaller than 10 microns (PM10), which may not be 

exceeded more than one day per year.

7.h 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 Available Control Technology 

(RACT), visible emissions, fallout, fugitive emissions, odors, emissions detrimental to persons or property, sulfur 

dioxide, concealment and masking, and fugitive dust.

7.i SWCAA 400-040(1) "Visible Emissions" requires that no emission 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.j 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.k SWCAA 400-040(3) "Fugitive Emissions" requires that reasonable precautions shall be taken to prevent the 

fugitive release of air contaminants to the atmosphere.

7.l SWCAA 400-040(4) "Odors" requires that any person who shall cause 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 must use recognized good practices and procedures to reduce these odors to a reasonable minimum.

7.m SWCAA 400-040(8) "Fugitive Dust Sources" requires that reasonable precautions be taken to prevent fugitive 

dust from becoming airborne, and minimize emissions.

7.n 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.o SWCAA 400-110 "New Source Review" requires that a Notice of Construction application be filed with SWCAA 

prior to the establishment of any new source, emission unit, or modification and that an Order of Approval be 

issued prior to establishment of the new source, emission unit, or modification.

7.p SWCAA 400-113 "Requirements for New Sources in Attainment or Nonclassifiable Areas" 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;
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(2) Best Available Control Technology will be employed for all air contaminants to be emitted by the 

proposed equipment;

(3) The proposed equipment will not cause any ambient air quality standard to be exceeded; and

(4) 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.

8. RACT/BACT/BART/LAER/PSD 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. Prevention of Significant Deterioration (PSD) Applicability: SWCAA has determined that this permitting action will 

not result in a potential increase in emissions equal to or greater than the PSD thresholds nor result in an increase 

greater than the significance thresholds, and therefore is not subject to PSD permitting. 

8.b Chromium Electroplating. The use of a fume suppressant that 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.c Nickel Electroplating. The use of a wetting agent that 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.d Copper and Gold Electroplating. The use of good work practice and no visible emissions meets the requirements of 

Best Available Control Technology (BACT) and Toxics BACT.

9. AMBIENT IMPACT ANALYSIS

9.a The plating facility proposed in NOC L-475 will emit TAPs. The TAP emissions associated with this permitting 

action have been quantified as follows:

9.1 Facilitywide Toxic Air Pollutant Emission Summary

Toxic

Compound CAS #

Total 

Annual 

Emissions 

(lb/yr)

Small 

Quantity 

Emission 

Rate 

(lb/yr)

Ambient 

Impact 

(μg/m3)

Acceptable 

Source Impact 

Level (μg/m3)

TAP 

Class

EPA Classified 

HAP (Yes/No)

Hexavalent 

Chromium

7440-47-3 0.21 ---- 0.000082 0.000083 

(Annual)

A Yes

Nickel and 

Compounds

7440-02-0 5.4 0.5 0.0021 0.0021 

(Annual)

A Yes

Copper Mist 7440-50-8 412 175 0.16 3.3 (24-hour) B No

Cyanide 51-12-5 12 1750 -- 17 (24-hour) B No

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, nickel and copper.

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, nickel nor 

copper greater than the acceptable source impact levels identified in WAC 173-460. The results of this modeling 

are shown in Table 9.1.
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Conclusions

9.c The electroplating facility, if installed and operated as proposed in NOC L-475 and if properly maintained, will 

not cause the ambient air quality requirements of Title 40 Code of Federal Regulations (CFR) Part 50 "National 

Primary and Secondary Ambient Air Quality Standards" to be violated.

9.d Installation of the electroplating facility, as proposed in NOC L-475 and previous NOC applications, 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 Carbon Monoxide, Ozone, and Nitrogen Dioxide"

to be violated.

9.e The electroplating facility proposed in NOC L-475, if properly installed and maintained, can be operated without 

causing a violation of emission standards for 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. DISCUSSION OF APPROVAL CONDITIONS

SWCAA has made a final determination to issue Order of Approval SWCAA 01-2354 in response to NOC L-475. Order 

of Approval SWCAA 01-2354 contains approval requirements deemed necessary to assure compliance with applicable 

regulations and emission standards as discussed below.

10.a Emission Limits for Electroplating Operations. SWCAA 01-2354 establishes the following emission limits for 

the facility:

Pollutant Emissions

Hexavalent Chromium 0.21 lb/yr

Nickel 5.4 lb/yr

Copper 412 lb/yr

Cyanide 12 lb/yr

The limits for hexavalent chromium were established to ensure that the facility will not exceed the ASILs for 

these components.

10.b Operating Limits and Requirements: Surface tension of the 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.

10.c Monitoring and Recordkeeping Requirements: Sufficient monitoring reporting and recordkeeping was 

established to document compliance with the established emission limits and provide for general requirements 

(e.g. upset reporting, annual emission inventory submission). Recordkeeping a 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."

10.d 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 15th. 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.
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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 review of possible pollution prevention measures for the 

facility. This facility will operate with limited process wastewater discharge and minimized amounts of 

dangerous wastes generated.

12. TUNING AND TESTING

12.a Testing Requirements. Emissions of hexavalent chromium from the electroplating facility will be tested initially 

within 120 days of initial operation. Emissions of nickel from electroplating will be tested one time if the facility

wishes to exceed the 1.87 million Amp-hr annual limit on nickel plating operations.

13. HISTORY

13.a General History. This electroplating facility is a new facility.

13.b Previous Approval Orders. None

13.c Compliance History. None

14. PUBLIC COMMENT

14.a Public/Applicant Comment for NOC L-475. No comment was received from the applicant or the public during 

the comment period.