### November 19 , 2010

Mr. Anthony

Sicilia Pacific NW Plating 700 1 NE 40 th 

### Avenue Vancouver, WA 98661 Dear Mr. Sicilia: 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 S WCAA staff on October 2 1, 2010
. This document contains a summary o f your facility's emission units and annual emissions, observations from SWCAA's inspection, applicable requirements/emission limits, and a compliance summary f or the facility

including identification of any violations, which were found. Iti s 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 S WCAA 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**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 management practices identified in 63.11507(g) have been implemented, as practicable; The wetting agent/fume s uppressant has been added to the nickel baths according to manufacturer’s spec ifications and instructions; A tank cover has been used on the strip tank at least 95% of the electrolytic process operating time. I hereby certify that the information present ed herein is correct to the best of my knowledge.

__________________________________ _______________________________

(Signature) (Date)

__________________________________ (

____)

_______________________

(Name/title) (Telephone No.)

### COMPLIA NCE EVALUATION REPORT ON
- SITE IN SPECTION Date of Inspection: October 21 , 2010 Date of Report: November 19 , 2010 Source Name: Pacific NW Plating SWCAA ID. No.: 2118 Physical Location: 700 1 NE 40 th Avenue , Vancouver, WA 98661 Mailing Address: 7001 NE 40 th Avenue, Vancouver, WA 98661 Telephone: (360) 735
- 9000 Fax: (360) 735
- 9001 Source Contact(s): Anthony Sicilia, Owner
-Manager Inspection Contact: Anthony Sicilia, Owner
-Manager AIRS No.: N/A Title V No ; Opt
- Out No SIC and/or NAICS: 3471/ 332813 AOP No. n/a ADPs : 02
-2442 R1 SWCAA Rep: Natalia Kreitzer Previous Inspection: September 29, 2009 Safety Equip.: Safety glasses, Dust Mask, S afety S hoes recommended Emission Inv. Year: 2 00 9 Emission Units: 4 200 9 Annual Emissions Potential to Emit (PTE) Criteria Emissions: VOC
- 0.00 tpy 0.00 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 tpy SO 2 - 0.00 tpy 0.00 tpy TAP Emissions:
- 0.0 1 tpy 0.05 tpy HAP Emissions:
- 0.0 1 tpy 0.0 5 tpy **A. Pr** **ocess Description/Background:** Pacific NW Plating is a metal finishing facility which electroplates various products with chromium, copper, nickel and zinc
. 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 Dis charge Permit 02
-2442 was the first air regulatory permit for this facility. Air Discharge Permit 02
-2442R1 was issued October 20, 2004 for the facility at its new location.**B. Emission Units/Control Equipment Descriptions:** 

EU 1 Chromic Acid Electroplating Tank. One chromic acid electroplating tank with a total surface area of 24 square feet (ft2) and a production capacity of 2,000 Amps. Emissions from the chromic acid tank 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. EU2 Nickel Electroplating Tanks. Five nickel electroplating tanks
. E ach nickel tank is 3’ wide, 8’ long and 4’deep. One 2,000 Ampere rectifi er supplies power to the five tanks
. The tanks are identified as Semibright (SB)1, SB2, Bright (B)1, B2 and B2
. Emissions from the nickel electroplating tanks are controlled with the use of the wetting agent, Infinity 2000 Air Wetter, which reduces surface tension and creates a foam blanket on the tank. One non
-resettable Amp
-hour meter serves all five nickel electroplating tanks. EU3 Copper Cyanide Electroplating Tank. One copper cyanide electroplating tank with a total surface area of 24 ft2 and a production capacity of 1,000 Amps. One non-resettable Amp
-hour meter is located on the copper cyanide electroplating tank. This tank is currently in limited operation. EU 4 Zinc Electroplating System. This system includes one zinc electroplating tank with a total surface area of 24 ft2 and a production capacity of 2,000 Amps with a non-resettable Amp
-hour meter, one HCl soap tank and one bright dip tank. The Zinc tank has been decommissioned, however Pacific NW Plating wished to keep the system permitted
. Other Equipment:  Grinding, buffing and polishing room with three units and an associated Oneida Air Systems cyclone separator.Facility Layout**C. Observations During Inspection**

I went to Pacific NW Plating f or an on- site insp ection on October 21 , 2010
. There was no noticeable nuisance odor or opacity coming from the building. I met with Mr. Sicilia who accompanied me on the inspection. We first went into the grinding/buffing/polishing room. Mr. Sicilia showed me all the required monitoring logs. Mr. Sicilia performs weekly dyne checks on the chrome tank and approximately every six months sends a sample to an independent laboratory for confirmation. Areview of the last year’s dyne checks indicated that surface tension was 35 dynes. The permit requirement is that this value always be below 45 dynes. No readings above 45 were noted. The nickel tank foam thickness is recorded weekly and Fumetrol 140 addition is recorded for each addition
. They only add a few ounces at a time. Plating Tanks Table 1: Information obtained for the tanks during the inspection.

**Tank Foam Height During** 

**Inspection Ampere** **- hrs meter**  **reading Ampere** **- hrs meter reading** 

**( 2008**  **inspection)** Chromic Acid Tank Not applicable 1 52,514 101,041 Nickel Plating Not Operating 00,001 1 99,185 Zinc Plating Tank Not applicable Not Installed Copper Plating Tank Not applicable Not Operating 1 Meter has turned over recently Mr. Sicilia submitted a Permit Application during the inspection to incorporate the additi onal nickel plating tanks as well as other future modifications to the facility including the addition of exhaust stacks. In addition, a HEPA filter has been installed on the exhaust vent over the plating area. **D. Reporting/Records Review:**  SWCAA received the 200 9 annual emission inventory information from Pacific NW Plating on March 9, 2010
. The records were being maintained as required see Appendix II for specific details. **E. Annual Emissions**  **:** The following emissions were calculated based on Pacific NW Plating’s March 9, 2010 submittal. Amp
hours submittal and emission factors presented in the facility’s Technical Support Document (TSD) for Air Discharge Permit 02
-2442R1: Hexavalent Chromium: 0.033 lb mi llion Am

p hr

 x 15,230 Amp
-hr = 0.000 5 lb 

### yr Nickel: 2.88 lb mi llion Am

p hr

 x 29,552 Amp
-hr = 0.0 9 lb 

### yr Copper: 66 lb mi llion Am

p hr

 x 100 Amp
-hr = 0.007 lb 

### yr Cyanide: 3.86 lb mi llion Am

p hr

 x 100 Amp
-hr = 0. 0004 lb 

### yr Zinc: 90 lb mi llion Am

p hr

 x 0 Amp
-hr = 0.0 lb



### yrHCl: 0.025 lb/hr x 10 hr/wk x 52 wk/yr = 13 lb/yr

Methanol (brightner 355): 0 1 gal x 9.27 lb gal x 1 0% = 0 lb



### yr 1 No brightner was purchased in 200 9 . Brightner is associated with the zinc line which is not in use. **F Compliance Assessment with Applicable Requirements/Emission Limits:**  A detailed account of observations made during the inspection is f ound in Appendix II of this document. **G. Compliance Summary:**  Pacific NW Plating is subject to 40 CFR 63 Subpart N: Chromium Electroplating NESHAP compliance requirements and 40 CFR 63.11504 et seq. (Subpart WWWWWW) “National Emiss ion 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 Pacific NW P lating 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

**Permit Number**  **App. #**  **Da te Issued**  **Desc ription**  02
-2442R1 CL
- 1650 October 20, 2004 Approved relocation of metal finishing facility and addition of a zinc plating system. 02
-2442 CL
- 1506 February 24, 2003 Approved metal finishing facility which will include electroplating of chromium, copper, and nickel . Superseded by APD 02
-2442R1.

### Appendix II **Compliance Summary All Requirements Contained in**  **Air Discharge Permit 02**  **- 2442**  **R1 No.**  **Permit Limit/Requirements Inspector’s Observation**  1. Combined emissions from plant operations shall not exceed:

Po llutant Emission Limit Hexavalent Chromium 0.033 lb/yr Nickel 3.25 lb/yr Copper 96 lb/yr Cyanide 5.6 lb/yr Zinc 135 lb/yr Methanol 333 lb/yr Hydrochloric Acid 110 lb/yr 2009 Emissions 0. 00 05 lb/yr 0.09 lb/yr 0.0 1 lb/yr 0.0 0004 lb/yr 0.0 lb/yr 0. 0 lb/yr 13 lb/yr 2. Emissions of toxic air pollutants shall not individually exceed SQER provided in WAC 173
-460 except those listed 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 detected 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 certi fied in accordance with SWCAA Method 9 (See Appendix A of SWCAA 400). No opacity observed

– stack not visible from ground 5. The surface tension of the chrome plating tank shall not exceed 45 dynes per centimeter. <3 5 dynes since last inspection . Last we ekly test indicated 33 dynes. Last independent analysis preformed on October 6, 2010 and indicated 31.9 dynes. 6. Foam blanket on the nickel tanks shall not be less than 1” during plating operations. Nickel tanks not operating during inspection. 7. The hydrochloric acid tank shall not be heated and shall be covered when not in use. Covered during inspection 8. Chrome plating operation shall not exceed 1,000,000 amp
-hour/year. 15,230 amp -hrs for 200 9 9. Nickel plating operation shall not exceed 1,100,00 0 amp
-hour/year. 29,552 amp -hrs for 200 9 10. Copper plating operation shall not exceed 1,460,000 amp
-hour/year. 10 0 amp -hrs for 200 9 11. Zinc plating operation shall not exceed 1,500,000 amp
-hour/year. 0 amp -hrs for 200 9 12. The plating solution liquid level shall be maintained  6" below top of each plating tank In compliance, tank levels 6
- 8” below top**No. Permit Limit/Requirements**  **Inspector’s Observation**

1 3
. The ampere -hour accumulators must be operating properly whenever electrical current is applied to the tank with one accumulator located on the chromium tank, one accumulator on both nickel tanks and one accumulator located on the copper tank. OK, amp ere -hour meters installed and appear to be running properly. Copper tank not in use. 14. The stack exhaust for the facility shall not be less than six feet above roof level and the exhaust area shall not exceed 4 square feet at the release point. No violation observed 15. VOC
-containing products shall be collected and stored in closed containers. No open containers observed 16. 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 nuisance odors detected offsite 17. Each pollution control device shall be operated whenever the processing equipment served by that control device is in operation. C ontrol devices shall be operated and maintained in accordance with the manufacturer's specifications. Furthermore, control devices shall be operated in a manner that minimizes emissions. No violation observed

1 8. Emission units identified in this Permit shall be maintained and operated in total and continuous conformity with the conditions identified in this Permit. S WCAA reserves the right to take any and all appropriate action to maintain the conditions of this Permit, including directing the facility to cease operations until corrective action can be completed. No indication of improper operation

1 9
. Surface tension of the chromium plating tank shall be recorded in the O/M log according to the following schedule: (a) Initially record every 4 hours of tank operation (or every 4
-amp hours if no hour meter installed) for 10 consecutive readings (b) If no violations occur, record every 8 hours of operation (or every 8
-amp hours if no hour meter installed) for 5 consecutive readings (c) If no violations occur, record every 40 hours of operation (or every 40
-amp hours if no hour meter installed) (d) If a violation occurs, the monitoring schedule must return to the frequency in 19.a for the specified time. Performing weekly dyne checks and recording results in maintenance log

20. Foam thickness on the nickel plating tank shall be recorded once per week no sooner than 30 minutes after the start of nickel plating operations. Recorded weekly in maintenance log 21. Ampere
-hour accumulator readings, calibration, and servicing shall be recorded in the O/M log monthly and shall contain the date and name for each entry. Recorded monthly in maintenance log 22. Fume suppressant usage shall be recorded in the O/M log for each addition and shall include quantity and time of addition. Recorded in maintenance log per addition**No. Permit Limit/Requirements**  **Inspector’s Observation**

23. Purchase receipts and MSDSs for all consumable products shall be retained on site for inspection by SWCAA. MSDSs kept in office 24. Each record required by this Permit 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. In compliance
25. All records required by this Permit shall be kept for a minimum period of no less than five years and shall be maintained in a form readily available for inspection by SWCAA representatives. In compliance 26. All upset conditions and/or excess emissions shall be recorded for each occurrence. No upset condition or upset emissions 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. In compliance
28. Upset conditions shall be reported to SWCAA as soon as possible in accordance with SWCAA 400
- 107. No upsets reported 29. Excess emissions shall be reported to SWCAA in accordance with SWCAA 400
- 107(1). Excess emissions which the permittee wishes to claim as unavoidable must be reported as soon as possible, but no later than 48 hours after discovery. No excess emissions reported
30. Operations of the electroplating facility shall be reported as follows:

(a) Amp
-hours of each meter Shall be reported to SWCAA annually by March 15 th (b) Zinc Bright Dip purchased Shall be reported to SWCAA annually by March 15 th (c) Summary of emissions Shall be reported to SWCAA annually by March 15 th

. Emission data received March 9 , 20 10**N o.**  **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) In compliance
- all tests show 3 5 dynes/cm or less 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. Aphone 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. In compliance
- nothing to report 63.343(b) Demonstration of initial compliance Exem pted 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 1 9 .a for the specified time. Weekly dyne checks are performed and recorded in maintenance log

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. Requirements incorporated into Air Discharge Permit 63.347(c)(2) Initial notifications of construction and start
-up . In compliance 63.347(h) Ongoing compliance status reports for area sources shal l be completed yearly in

accordance with this section. The report shall be maintained on site and available for inspection upon request. 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 non- cyanide 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. This also applies to the strip tank since the strip tank appears to meet the definition of an electropolishing tank. Pacific NW Plating is using Infinity 2000 Air Wetter on the nickel tanks. SWCAA is working with Miles Chemical to get information that this product meets the definition of a wetting agents. Control of the electropolishing tank is achieved by covering tank surface during operation. 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 Tony, 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, 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
. PNW Plating performs these workplace practices where practical.

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 m ust 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.