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 Director
Southwest 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 Operations
Southwest 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 be 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/yr

Nickel 5.4 lb/yr

Copper 412 lb/yr

Cyanide 12 lb/yr

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 good 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 Certified Observer certified in accordance with 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 dynes 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. 1
Southwest 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 testing 

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. Doors 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. SWCAA 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 operation

(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.

1
Southwest 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 this 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 Amphours 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 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. 

Plantwide

28. Upset conditions shall be reported to SWCAA as soon as possible in accordance with 

SWCAA 400-107.

Plantwide

29. 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) Summary of emissions Shall be reported to SWCAA annually by 

March 15th.

Plantwide

3. General Provisions

No. General Provisions

A. 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. 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. SWCAA 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 authorized 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, employees, 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 portion 

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 be specifically set 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 applicable 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 at 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 of 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 of 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 production 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 analytical 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 certifying the validity of the 

source test report.
August 13, 2003

Keith Henderson

504 NE 2nd St.

Winlock, WA 98596

Subject: Final Approval for Installation 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 your final Order of Approval.

This Order of Approval may be appealed directly to the Pollution Control Hearings Board (PCHB) 

at PO Box 40903, Olympia, Washington 98504-0903 within 30 days of receipt of this Order as 

provided in RCW 43.21B.

Thank you for your 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