**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 AgencySWCAA 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. Re gulations and Emission Standards 3 8. RACT/BACT/BART/LAER/PSD Determinations 5 9. Am bient 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 7SWCAA 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 H2 SO 4 Sulfuric acid HAP Hazardous air pollutant listed pursuant to Section 112 of the Federal Clean Air Act HCl Hydrochl oric 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 CodeTechnical Support Document NOC L
-475 Specialty Stainless & Aluminum, Inc. SWCAA 01
-2354

1 **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 Co de: 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 (H2 SO 4) 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.Technical Support Document NOC L
-475 Specialty Stainless & Aluminum, Inc. SWCAA 01
-2354

2 5.b Nickel Electroplating Tank. One nickel electroplating tank with a surface area of 12 ft2 and 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 ft2 and 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 ft2 and a production capacity of 25 Amps. One non
-resettable Amp
-hour meter will be located on the gold electroplating tank. **6. EMISSIONS DE TERMINATION**  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 mi llion Am

p hr

 x 6.24 mi llion Am

p - 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 p ercent. 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 1.87 mi llion Am

p - 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 mi llion Am

p hr

 x 6.24 mi llion Am

p - 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:Technical Support Document NOC L
-475 Specialty Stainless & Aluminum, Inc. SWCAA 01
-2354

3 3.86 lb mi llion Am

p hr

 x 3.12 mi llion Am

p - 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 mi llion Am

p hr

 x 0.078 mi llion Am

p - 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 * 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 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 

### * 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 i s 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 e lectroplating based 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.c Revi sed 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.Technical Support Document NOC L
-475 Specialty Stainless & Aluminum, Inc. SWCAA 01
-2354

4 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 "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.h SWCAA 400
- 040 "General Standards for Maximum Emissions" requires all new and exi sting 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 releas e 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 Revi ew" 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 modi fication. 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;Technical Support Document NOC L
-475 Specialty Stainless & Aluminum, Inc. SWCAA 01
-2354

5 (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) Am

bient 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.Technical Support Document NOC L
-475 Specialty Stainless & Aluminum, Inc. SWCAA 01
-2354

6 **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 Car bon 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 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 emi ssions must be reported promptly, consistent with SWCAA 400
- 107.Technical Support Document NOC L
-475 Specialty Stainless & Aluminum, Inc. SWCAA 01
-2354

7 **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.