November 19, 2010

Mr. Anthony Sicilia

Pacific NW Plating

7001 NE 40th 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 SWCAA staff on October 21, 2010. This document contains a summary of your facility's 

emission units and annual emissions, observations from SWCAA's inspection, applicable 

requirements/emission limits, and a compliance summary for the facility including identification 

of any violations, which were found. It is your ongoing responsibility to maintain continuous 

compliance with all of the applicable air pollution control requirements for your facility as 

defined and referenced in SWCAA's regulations (400 through 493) and any SWCAA Air 

Discharge Permits which have been issued for your facility, as well as any state (WAC 173) and 

federal (40 CFR) regulations which apply. 

Please review this document carefully and note that any information contained within it is 

considered public domain and not confidential. If you find any discrepancies or have any

questions, please contact me at (360) 574-3058 extension 114. 

Sincerely,

Natalia Kreitzer

Air Quality Engineer

Enclosure
Annual Compliance Certification

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

This facility IS operating in compliance with all of the relevant standards and other requirements 

of 40 CFR Part 63 subpart WWWWWW, National Emission Standards for Hazardous Air 

Pollutants: Area Source Standards for Plating and Polishing Operations as follows:

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

practicable;

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

manufacturer’s specifications and instructions;

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 presented herein is correct to the best of my knowledge.

__________________________________ _______________________________

 (Signature) (Date)

__________________________________ (____)_______________________

 (Name/title) (Telephone No.)

 
COMPLIANCE EVALUATION REPORT

ON-SITE INSPECTION

Date of Inspection: October 21, 2010 Date of Report: November 19, 2010

Source Name: Pacific NW Plating

SWCAA ID. No.: 2118

Physical Location: 7001 NE 40th Avenue, Vancouver, WA 98661

Mailing Address: 7001 NE 40th 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: 02-2442R1

SWCAA Rep: Natalia Kreitzer

Previous Inspection: September 29, 2009

Safety Equip.: Safety glasses, Dust Mask, Safety Shoes recommended

Emission Inv. Year: 2009

Emission Units: 4

2009 Annual Emissions Potential to Emit (PTE)

Criteria Emissions: VOC - 0.00 tpy 0.00 tpy

NOx - 0.00 tpy 0.00 tpy

CO - 0.00 tpy 0.00 tpy

PM - 0.00 tpy <0.01 tpy

PM10 - 0.00 tpy <0.01 tpy

PM2.5 - 0.00 tpy <0.01 tpy

SO2 - 0.00 tpy 0.00 tpy

TAP Emissions: - 0.01 tpy 0.05 tpy

HAP Emissions: - 0.01 tpy 0.05 tpy

A. Process 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 Discharge 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:

EU1 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. Each nickel tank is 3’ wide, 8’ 

long and 4’deep. One 2,000 Ampere rectifier 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 ft2and 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 ft2and 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 for an on-site inspection 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. A review 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 152,514 101,041

Nickel Plating Not Operating 00,001199,185

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 additional 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 2009 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. Amphours submittal and emission factors presented in the facility’s Technical Support Document (TSD) for 

Air Discharge Permit 02-2442R1:

Hexavalent Chromium: 0.033 

lb

million Amp  hr

x 15,230 Amp-hr = 0.0005

lb

yr

Nickel: 2.88 

lb

million Amp  hr

x 29,552 Amp-hr = 0.09

lb

yr

Copper: 66 

lb

million Amp  hr

x 100 Amp-hr = 0.007

lb

yr

Cyanide: 3.86 

lb

million Amp  hr

x 100 Amp-hr = 0.0004

lb

yr

Zinc: 90 

lb

million Amp  hr

x 0 Amp-hr = 0.0 

lb

yr
HCl: 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 10% = 0 

lb

yr

1 No brightner was purchased in 2009. 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 found 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 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 Pacific NW Plating facility. This facility is not subject to any other 

NSPS, MACT, or NESHAP.

H. Appendices and Attachments: 

I Regulatory Permit Summary

II Compliance Assessment
Appendix I

Regulatory Permit Summary

Permit Number App. # Date Issued Description

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 02-2442R1

No. Permit Limit/Requirements Inspector’s Observation

1. Combined emissions from plant operations shall not exceed:

Pollutant 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

0.0005 lb/yr

0.09 lb/yr

0.01 lb/yr

0.00004 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 certified 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. <35 dynes since last inspection. Last 

weekly 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 2009

9. Nickel plating operation shall not exceed 1,100,000 amp-hour/year. 29,552 amp-hrs for 2009

10. Copper plating operation shall not exceed 1,460,000 amp-hour/year. 100 amp-hrs for 2009

11. Zinc plating operation shall not exceed 1,500,000 amp-hour/year. 0 amp-hrs for 2009

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

13. 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, ampere-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. Control 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

18. Emission units identified in this Permit shall be maintained and operated in total and continuous 

conformity with the conditions identified in this Permit. SWCAA 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

19. 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 15th

(b) Zinc Bright Dip purchased Shall be reported to SWCAA annually by March 15th

(c) Summary of emissions Shall be reported to SWCAA annually by March 

15th.

Emission data received March 9, 2010

No. 40 CFR 63 Subpart N NESHAP Requirements Inspector’s Observation

63.342(d)(2) If using a wetting agent, not to allow the surface tension of the electroplating tank to 

exceed 45 dynes per centimeter (dynes/cm)

In compliance - all tests show 35 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. A phone report shall be submitted within two 

working days after periods of malfunction that are inconsistent with the operations and 

maintenance plan with a follow up letter within seven working days.

In compliance - nothing to report

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.

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 shall 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, 2008
63.11509(c) You must prepare an annual certification of compliance report

(1) You must state in your annual compliance certification that you have added 

wetting agent/fume suppressant to the bath according to the manufacturer’s 

specifications and instructions

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

maintained the control system according to the manufacturer’s specifications 

and instructions

(3) You must state in your annual compliance certification that you have 

implemented the applicable management practices as practicable

(4) Each annual compliance report must be prepared no later than January 31 of the 

year immediately following the reporting period and kept in a readily accessible 

location for inspector review. If a deviation has occurred during the year, each 

annual compliance report must be submitted along with the deviation report 

postmarked or delivered no later than January 31.

The compliance date for this regulation is 

July 1, 2010. Therefore the first annual 

certification of compliance must be 

completed by January 31, 2011.