**SOUTHWEST CLEAN AIR AGENCY**

**ORDER of APPROVAL SWCAA 01**  **- 2354**  **Final Issue Date: August 13, 2003** 

Facility Name: Specialty Stainless & Aluminum, Inc. Physical Location: 524 N Gold Street

Centralia, WA 98531 SWCAA ID: 2113

REVIEWED BY: Paul T. Mairose, Chief Engineer

APPROVED BY: Robert D. Elliott, Executive DirectorSouthwest Clean Air Agency Order of Approval

SWCAA 02 - 2442 

### TABLE OF CONTENTS

Section Page 1. Equipment/Activity

Identification 1 2. Permit Terms and Conditions 1 2.1 Emission Limits 1 2.2 Operating Limits and Requirements 1 2.3 Monitoring and Recordkeeping Requirements 2 2.4 Tuning and Testing Requirements 3 2.5 Reporting Requirements 3 3. General Provisions 3 Appendix A Emission Testing Requirements Plating OperationsSouthwest Clean Air Agency Order of Approval

SWCAA 01 -2354 1 

### 1. Equipment/Activity Identification This facility

consists of one emission unit, electroplating, with the following equipment: **ID No. Equipment/Activity**  **# of Units**  **Control Equipment # of**  **Units** 1 Chromium Electroplating 1 Fumetrol #140 Fume Suppresant 1 2 Nickel Electroplating 1 Wetting Agent 1 3 Copper Electroplating 2 None 4 Gold Electroplating 1 None 

### 2. Permit Terms and Conditions The following tables detail the specific terms and conditions of this permit. In addition to the requirements listed below, equipment at this facility may b e subject to additional federal, state, and local regulations. The permit term or requirement number is identified in the left hand column. The permit term or requirement is contained in the middle column . The emission unit, equipment, or activity to which the permit term or condition applies is listed in the right hand column. **2.1 Emission Limits No.**  **Emission Limits Equipment/**  **Activity** 1. Combined emissions from plant operations shall not exceed: Pollutant Emission Limit Hexavalent Chromium 0.21 lb/y r Nickel 5.4 lb/y r Copper 412 lb/y r Cyanide 12 lb/y r Emissions shall be calculated based on the methodology outlined in Section 6 of the Technical Support Document for this Order of Approval. Plantwide

2. Emissions of toxic air pollutants shall not individually exceed the SQER provided in WAC 173 -460 except those listed in condition 1 above. Plantwide 3. Emissions to the atmosphere which cause or contribute to a nuisance odor shall use recognized go od practice and procedures to reduce these odors to a reasonable minimum. Plantwide 4. Visible emissions shall not exceed zero percent opacity for more than 3 minutes in any one hour period as determined by a C ertified Observer certified in accordance wit h SWCAA Method 9 (See Appendix A of SWCAA 400). Plantwide
**2.2 Operating Limits and Requirements No.**  **Operating Limits**  **and Requirements Equipment/**  **Activity** 5. The surface tension of the chrome plating tank shall not exceed 45 dy nes per centimeter. 1 6. The foam blanket on the nickel tank shall not be less than 1” during plating operations. 2 7. Chrome plating operation shall not exceed 6.24 million amp
-hour/year. 1Southwest Clean Air Agency Order of Approval

SWCAA 01 -2354 2 **No. Operating**  **Limits and Requirements**  **Equipment/ Activity**  8. Nickel plating operation shall not exceed 1.87 million amp -hour/year unless source te sting is performed and demonstrates that compliance with the nickel emission limit in 1. above can be met at a higher annual nickel plating amp
-hour level. 2
9. Copper plating operation shall not exceed 6.24 million amp
-hour/year. 3 10. The plating solution liquid level shall be maintained at least 6" below the top of the tank. 1 -4 11. The building exhaust must be no less than 28 feet above ground level. 1 -4 12. Open doors shall be prohibited during plating operations except to move equipment/materials into or out of the building. D oors shall be closed immediately after equipment/materials are transferred into/out of the building. 1 -4
13. Ampere -hour accumulators must be operating properly whenever electrical current is applied to tank with one accumulator located on the chromium tank, one accumulator on the nickel tank, one accumulator located on both copper tanks and one accumulator located on the gold tank. 1 -4

14. VOC containing products shall be collected and stored in closed containers. Plantwide 15. Operations that cause or contribute to a nuisance odor shall use recognized good practice and procedures to reduce these odors to a reasonable minimum. Plantwide 16. Emission units identified in this Order shall be maintained and operated in total and continuous conformity

with the emission levels and operational requirements specified in this Order. S WCAA reserves the right to take any and all appropriate action to maintain the conditions of this Order, including directing the facility to cease operations until corrective action can be completed. 1 -4

**2.3 Monitoring and Record Keeping Requirements No.**  **Monitoring and Record Keeping Requirements**  **Equipment/ Activity**  17. The surface tension of the chromium plating tank shall be recorded in an O/M log according to the following schedule: (a) Initially

record every

4 hours of tank operation for 10 consecutive readings (b) If no violations occur, record every 8 hours of operation for 5 consecutive readings (c) If no violations occur, record every 40 hours of operati on (d) If a violation occurs, the monitoring schedule must return to the frequency in 16.a for the specified time. 1

18. Foam thickness on the nickel plating tank shall be recorded once per week no sooner than 30 minutes after start of nickel plating operations. 2 19. Ampere -hour accumulator readings, calibration, and servicing shall be recorded in the O/M log monthly; each entry shall contain date and name for each entry. 1 -4 20. Fume suppressant use shall be recorded in the O/M log for each addition and shall include quantity and time of addition. 1Southwest Clean Air Agency Order of Approval

SWCAA 01 -2354 3 **No. Monitoring**  **and Record Keeping Requirements Equipment/**  **Activity** 21. Purchase receipts and MSDSs for all consumable products shall be retained on site for inspection by

SWCAA. Plantwide 22. Each record required by this Order 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. Plantwide
23. All records required by t his Order shall be kept on site for a minimum period of no less than five years and shall be available for inspection by SWCAA representatives. Plantwide 24. All upset conditions and/or excess emissions shall be recorded for each occurrence. Plantwide **2.4 Tuning and Testing Requirements No.**  **Tuning and Testing Requirements Equipment/**  **Activity** 25. Hexavalent chromium plating operations shall be emission tested within 120 days of initial operation in accordance with Appendix A of this Order. 1 26. Nickel plating operations shall be emission tested prior to exceeding 1.87 million Amp hours of operation per year in accordance with Appendix A of this Order. 2 **2.5 Reporting Requirements No.**  **Reporting Requirements Equipment/**  **Activity** 27. The permittee shall notify S WCAA 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. Plantwide
28. Upset conditions shall be reported to SWCAA as soon as possible in accordance with SWCAA 400 - 107. Plantwide 29. Op erations 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) Summary

of emissions Shall be reported to SWCAA annually b y March 15 th

. Plantwide



### 3. General P **rovisions No.**  **General Provisions** A. The permittee shall notify S WCAA 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. The equipment and activities specified in Notice of Construction L- 475 shall be maintained and operated in total and continuous conformity with the emission levels identified in this Order. S WCAA reserves the right to take any and all appropriate action to maintain the conditions of this Order, including directing the facility to cease operations until corrective action can be completed.Southwest Clean Air Agency Order of Approval

SWCAA 01 -2354 4 **No. General Provisions**  B. For the purpose of ensuring compliance with this Order, duly a uthorized representatives of the Southwest Clean Air Agency shall be permitted access to the permittee's premises and the facilities being constructed, owned, operated and/or maintained by the permittee for the purpose of inspecting said facilities. These inspections are required to determine the status of compliance with this Order and applicable regulations and to perform or require such tests as may be deemed necessary. C. The provisions, terms and conditions of this Order shall be deemed to bind the permittee , its officers, directors, agents, servants, employe es, successors and assigns, and all persons, firms, and corporations acting under or for the permittee . D. The requirements of this Order shall survive any transfer of ownership of the source or any p ortion thereof. E. This Order shall be posted conspicuously at or be readily

available near the source. F. This Order shall be invalid if construction/installation has not commenced within eighteen months from date of issuance. G. This Order does not supersede requirements of other Agencies with jurisdiction and further, this Order does not relieve the permittee of any requirements of any

other governmental Agency. In addition to this Order, the permittee may

be required to obtain permits or approvals from other agencies with jurisdiction. H. Compliance with the terms of this Order does not relieve the permittee from the responsibility of compliance with SWCAA General Regulations for Air Pollution Sources, previously issued Regulatory Orders, RCW 70.94, Title 173 WAC or any other applicable emission control requirements, nor from the resulting liabilities and/or legal remedies for failure to comply. I. If any

provision of this Order is held to be invalid, all unaffected provisions of the Order shall remain in effect and be enforceable. J. No change in this Order shall be made or be effective except as may b e specifically

s et forth by

written order of the Southwest Clean Air Agency upon written application by the permittee for the relief sought. K. The permittee shall have the burden of proof regarding unavoidable conditions that lead to excess emissions in accordance with SWCAA 400 - 107 "Excess Emissions." Excess emissions shall be reported to SWCAA as soon as possible. The permittee shall call in the upset condition via telephone as initial notification to SWCAA; a message may be left on the answering machine for conditions outside of normal business hours. The permittee shall record the upset conditions in the operations log for periodic inspection by

SWCAA. A full report may be required by

SWCAA if determined to be necessary. L. The Southwest Clean Air Agency may, in accordance with RCW 70.94 impose such conditions as are reasonably

necessary to assure the maintenance of compliance with the terms of this Order, the Washington Clean Air Act, and the a pplicable rules and regulations adopted under the Washington Clean Air Act.

### Order of Approval SWCAA 01 **- 2354**  **- Appendix A**  **Page 1 of 2** 

### Emission Testing Requirements **Plating Operations 1.**  **Introduction:** a. The purpose of this testing is to quantify emissions from plating operations, and to demonstrate compliance with the requirements of this Order of Approval. b. Emission testing shall be performed for hexavalent chromium within 120 days of initial operation of the facility. Emission testing shall be performed for nickel prior to exceeding 1.87 million Amp -hours of annual operation. c. Emission testing shall include, but is not necessarily limited to, the constituents identified in Section 2.a below. A minimum of three test runs a t normal operating conditions shall be performed to ensure that the data are representative. Each test run shall be at least two hours long. d. A comprehensive test plan shall be submitted to SWCAA for review and approval 10 business days prior to each test. e. SWCAA personnel shall be informed at least five business days prior to testing so that they may be present during testing. **2. Testing Requirements:**  a. Constituents to be measured: Test Methods or Equivalent: (1) Volumetric flow rate, gas velocity, EPA Methods 1 & 2 and temperature (2) Exhaust gas moisture content EPA Method 4 (3) Hexavalent chromium EPA Method 306 (4) Nickel EPA Method 29 b. Outlet of building exhaust shall be tested for constituents 2.a.(1) through 2.a.(3) for hexavalent chromium testing and constituents 2.a.(1), 2.a.(2) and 2.a.(4) for nickel testing. **3. Source Operation:**  a. A complete record of production related parameters including process startups, shutdowns, and adjustments shall be kept during emissions testing to correlate operations with emissions, and shall be recorded in the final test report. b. Source operations during the emissions test must be representative of the maximum level of normal operation.

### Order of Approval SWCAA **01 -** **2354 -**  **Appendix A Page 2 of 2**  

### Emission Testing Requirements **Plating Operations 4.**  **Reporting Requirements:** a. A final emission test report shall be prepared and submitted to SWCAA within 45 calendar days of test completion and, at a minimum, shall contain the following information: (1) Description of the source including manufacturer, model number and design capacity o f the equipment, and the location of the sample ports or test locations, (2) Time and date of the test and identification and qualifications of the personnel involved, (3) Summary

o f results, reported in units and averaging periods consistent with the application emissions standard or unit, (4) Summary

of control system or equipment operating conditions, (5) Summary

of producti on related parameters, (6) A description of the test methods or procedures used including all field data, quality assurance/quality control procedures and documentation, (7) A description of the analy tical procedures used including all laboratory data, quality

assurance/quality control procedures and documentation, (8) Copies of field data and example calculations, (9) Chain of custody

information, (10) Calibration documentation, (11) Discussion of any

abnormalities associated with the results, and (12) A statement signed by the senior management official of the testing firm certify ing the validity

o f the source test report.August 13, 2003

Keith Henderson 504 NE 2 nd St. Winlock, WA 98596 Subject: Final Approval for I nstallation of a New Electroplating Facility Dear Mr. Henderson: We have not received any adverse response from the public relative to the Preliminary Determination of Order of Approval SWCAA 01 -2354 for your Notice of Construction Number L475 submittal. We are pleased to issue y our final Order of Approval. This Order of Approval may b e appealed directly

to the Pollution Control Hearings Board (PCHB) at PO Box 40903, Oly

mpia, Washington 98504 - 0903 within 30 days of receipt of this Order as provided in RCW 43.21B. Thank you for y

our attention in this matter. Sincerely, Robert D. Elliott Executive Director RDE:nk Attachment cc: Ray

Nye (NESHAP Subpart N) Federal & Delegated Programs Unit US EPA Region X 1200 6th Avenue, AT
- 082 Seattle, WA 98101