AIR POLLUTION CONTROL COMPLIANCE INSPECTION

SUMMARY SHEET

County Number County Source Number

 031 0129

Company DENVER METAL FINISHING 

Site Location: 3100 E 43RD AVE

Zip Code: 80216-

Contact ANDREW EBEN

Title: CHEMIST

Telephone Number: 3032951380

Permit Number(s): APEN Expiration 

99DE0081E 5/6/2009

91DE815 

Compliance Inspection 7/26/2006

Compliance Report Date: 7/28/2006

Inspector: Amy S. Wiley

Inspection Type MACT

Storm Water 

RCRA Screening 

Air Inspection 

Pre-Inspection 2

Inspection: 2

Travel: 0.5

Report: 3

Total Hours: 7.5

Follow-up Inspection 

Reinspection Hours: 0

Compliance Assistance P2 Information 

Revised or New APEN Required:

Date Revised or New APEN Due to 

Compliance Advisory 

Compliance Advisory 
AIR POLLUTION CONTROL FIELD INSPECTION WORKSHEET

FACILITY NAME DENVER METAL FINISHING

SOURCE NUMBER 129

A. GENERAL FACILITY DESCRIPTION

This source is an electroplating facility located in a largely residential neighborhood in North 

Denver.

B. COMPLIANCE HISTORY

A compliance advisory was issued Denver Metal Finishing March 31, 1999. The company was 

found to be in violation of 40 CFR, Part 63 Subpart N for not adhering to surface tension 

requirements on 3 occasions in 1998 and 1999. In addition, the company did not monitor surface 

tension as required after exceeding surface tension limits. An Order on Consent was signed 

5/16/2000, and the case was considered closed as of September 7, 2000. There have been further 

enforcement actions at the time of this inspection.

C. PROCESS DESCRIPTION

This source is a job shop plating facility that has both hard chrome and decorative chrome 

processes utilizing hexavalent chromium, in addition to zinc, nickle, tin, copper and gold plating. 

This is a typical plating operation, with caustic and acidic cleaning and rinsing baths in addition 

to the various electroplating solutions. Denver Metal Finishing has recently purchased a new 

facility in Adams County. Current plans are to shut down Denver operations in 2007.

D. EMISSION POINT EVALUATION

1. Emission Point 003 - Exempt

Emission point 003 refers to natural gas usage in two small boilers at the facility. At 2.1 

million BTU/hr and 2.4 million BTU/hr, these units are now specifically exempt from 

reporting requirements. The source informed the Division in writing on February 5, 

1999.

2. Emission Point 004 - Exempt

Emission point 004 refers to emissions from the grinding/polishing operation at this 

facility. On February 5, 1999 the source informed the Division that uncontrolled actual 

emissions from this point were 500 lbs per year, and that the point was exempt from 

reporting requirements.

3. Chromium Electroplating

This source has three hard chrome plating tanks and one decorative chrome plating tank. 

This facility is subject to the Chromium Electroplating MACT. 
E. GENERAL FACILITY COMPLIANCE

This facility is subject to the Chromium Electroplating MACT. “Field Inspection Reports” for 

Decorative and Hard Chromium Electroplating Tanks are included in this report.
Field Inspection Report for

Decorative Chromium Electroplating Tank Using a Hexavalent Solution, with 

a Wetting Agent AS AN ADDITIVE

To fit within this category, the operator must demonstrate that a wetting agent is added to the 

trivalent or hexavalent bath solution. A wetting agent is a fume suppressant that limits the 

emissions of chromium fumes by decreasing the surface tension of the bath. A wetting agent 

that is added to the trivalent solution by the operator is an additive, not an ingredient in the 

solution.

If a wetting agent is an ingredient in the trivalent bath solution, the operator must comply with 

the requirements for a Decorative Chromium Electroplating Tank Using a Trivalent Solution 

with a Wetting Agent as an Ingredient. If you are unclear as to whether the wetting agent is an 

ingredient or additive please contact the Air Pollution Control Division at 692-3269.

COUNTY NUMBER: 031 SOURCE NUMBER: 0129 INSP. DATE:

07/24/2006

COMPANY: DENVER METAL FINISHING

SITE LOCATION: 3100 E. 43RD AVE COUNTY:

DENVER

INSPECTOR: AMY S. WILEY

CONTACT PERSON: ANDY EBEN OR KERRY MORGAN

TELEPHONE NO.: 303-295-1380

CONSTRUCTION PERMIT NO.:

ISSUANCE DATE:

INSPECTION TYPE:ROUTINE [ X ] COMPLAINT [ ]

NSPS &/or MACT Applicability: National Emission Standards for Chromium Emissions 

from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (a.k.a. 

MACT) - 40 CFR 63, Subparts A & N apply to this source.

P2 Assistance Given: Y Compliance Assistance Given: N

A. Basic plating information:

1. What is the rectifier capacity of each of the tanks at this facility?

________________________________________________________________________

______

___TANK # 101 - 2000 AMPS 

________________________________________________

________________________________________________________________________

______
2. On what date was each electroplating tank(s) installed?

________________________________________________________________________

______

______1967______________________________________________________________

______

________________________________________________________________________

______
3. How are the tanks run or operated?

Is the same residence time used throughout the process? _

What are volts/amps for the process? 

RANGES BETWEEN 15 

SECONDS AND TWO MINUTES.______

How does the company track operating time of the tank? ___

_BEGINS AT APPROXIMATELY 5 VOLTS, 

INCREASES TO 10 VOLTS, THEN FINISHES AT 5 VOLTS 

_

Does the operator use an air sparge in the tank? If yes, please explain why and what you 

informed them about the use of an air sparge: 

HOUR 

METER._______________

____NO_________________ 

________________

4. Other comments on operation and condition of the tanks (i.e., corrosion on tanks):

________________________________________________________

______

________________________________________________________________________

______

B. Reports: The operator must submit the following reports for decorative chromium 

electroplating tanks using trivalent or hexavalent solution with a wetting agent as an 

additive to U.S. EPA and the Division. 

1. Did the operator make a change to the trivalent or hexavalent chromium electroplating 

process since February 24, 1996 (circle one)? Yes No

_____ If yes, did the operator submit a report within 30 days of the change that includes 

the following?

a. A description of the manner in which the process has been changed and the 

emission limit, if any, now applicable to the tank;

b. If a different emission limit applies, the applicable information required by this 

regulation for that emission limit (contact the APCD at 692-3269); and

c. The notification and reporting requirements that are required by this regulation for 

that type of process (contact the APCD at 692-3269).

If no for any of the reasons in a, b, or c, please explain below:

________________________________________________________________________

_____
2. Has the company installed a new chromium electroplating tank or modified an existing 

tank after January 25, 1995 (circle one)? Yes No

_____ If yes, did the operator submit to the Division a notification of 

construction or reconstruction or process change? If no notification was 

submitted, please explain:

________________________________________________________________________

_____

3. Has the company switched from the current chromium electroplating process to another 

type of plating process (e.g., from trivalent to hexavalent) (circle one)? Yes No

_____ If yes, did the operator submit to the Division a notification of a process 

change? If no notification was submitted, please explain:

________________________________________________________________________

_____

4. _YES_

________________________________________________________________________

_____

Has the operator developed ongoing compliance status reports that 

demonstrate ongoing compliance with Subpart N on an annual basis? If no, 

please explain:

5. Is the operator required by an order or other stationary source regulation of the Colorado Air 

Quality Control Commission to maintain any other records (circle one)?

Yes No

_____ If yes, were the records properly maintained? If no, please explain:

________________________________________________________________________

_____

C. Ongoing Compliance Monitoring: The operator must conduct ongoing compliance 

monitoring in the form of surface tension measurements technically correctly and often 

enough. This monitoring shows the Division that emissions from the source are 

continually below 45 dynes/cm. When an exceedance does occur it must be documented 

and kept on file at the facility.

1. What type of wetting agent does the facility use? Has the facility had any problems with 

the wetting agent (i.e., causes pitting, doesn’t cover entire surface)?

__FUMETROL 140. NO PROBLEMS REPORTED.

2. How often does the facility add the wetting agent? When do the operators know wetting 

agent needs to be added?

__THE FACILITY ADDS WETTING AGENT WHENEVER THE SURFACE 

TENSION MEASUREMENT APPROACHES 40 DYNES, OR IF A LARGE JOB IS 

ANTICIPATED. TIMING DEPENDS ON TANK USE. 

_____________________________
3. How often does the facility measure the surface tension of each tank?

_

__EVERY 40 HOURS OF OPERATION AS DETERMINED BY THE HOUR METER. 

____

YES_Did the operator measure and record the surface tension for the first 40 hours, 

once every 4 hours, and, if the surface tension is less than or equal to 45 

dynes/dscm, then,

_YES_Did the operator measure and record the surface tension for the next 40 hours, 

once every 8 hours, and, if the surface tension is less than or equal to 45 

dynes/dscm, then,

_YES_

If the operator failed to comply with the above monitoring schedule, please explain:

Did the operator measure and record the surface tension once every 40 hours and 

continue with this schedule?

________________________________________________________________________

______

Did the surface tension measurements at any time exceed 45 dynes/dscm (circle one)?

Yes No

Did the operator change the tank solution at any time (circle one)? Yes No

_____ If yes to either of the above questions, did the operator resume the original 

monitoring schedule described above? If no, please explain:

________________________________________________________________________

______

4. Ask that the operator demonstrate the taking of a surface tension sample.

_YES_

________________________________________________________________________

______

Did he/she follow the correct procedure (i.e., thoroughly clean stalagmometer, 

correctly measure surface tension)? If no, please describe the deficiencies in the 

procedure used:

D. Emission Limits: The operator must meet the following emission limit for each tank 

using a trivalent or hexavalent bath with a wetting agent as an additive. Based upon 

records maintained by the company:

_YES_

_____ If no, did the operator record the excess emissions and maintain the record onsite?

Did the company maintain the surface tension at or below 45 dynes/cm since 

January 25, 1996 or the last inspection?

If the operator did not comply with the surface tension standard and/or failed to maintain 

excess emission records, please explain.

________________________________________________________________________

______

E. Operating and Maintenance Plan: The Operator must develop an Operation and 

Maintenance plan (O&M plan) and implement it no later than the stated implementation 

date. The O&M plan must incorporate work practice standards for any surface tension 
monitoring equipment as discussed above. The Operator must at all times including 

periods of startup, shutdown, and malfunctions, and operate and maintain any affected 

equipment consistent with the O&M plan. The Operator must ensure that the following 

is done.

1. Development of Operation and Maintenance Plan

_YES_Did the operator develop an Operation and Maintenance Plan?

_YES_

If no was answered to any of the above, please explain:

Was the operator able to provide you with a copy during the inspection?

________________________________________________________________________

______

2. Content of Operation and Maintenance Plan

_YES_

a. a description of the surface tension monitoring system(s) for the process and 

pollution control systems;

Upon review of the Operation and Maintenance Plan, did it meet the basic 

requirements described below?

b. a checklist to document the operation and maintenance done on the equipment;

c. a description of the operating procedures from the manufacturer; and

d. procedures to follow to ensure that equipment or process malfunctions due to poor 

maintenance or other preventable conditions do not occur.

_YES_

a. tank(s) and associated ductwork, and

Did the Operator operate and maintain the following according to the O&M plan:

b. air pollution monitoring equipment?

If no was answered to any of the above, please explain:

________________________________________________________________________

______

3. Were there any upsets or malfunctions involving the tanks (circle one)? Yes

No

_____ If yes, did the Operation and Maintenance Plan address the malfunctions and 

corrections of malfunctions and did the operator comply with the plan during 

those periods?

_____ If the plan was not complied with, did the operator revise the plan?

If no to either of the above questions, please explain:

________________________________________________________________________

______

F. Recordkeeping: The operator must maintain the proper recordkeeping. The records 

must be made available to the Division, local inspectors, and U.S. EPA and maintained 

for at least 5 years.

1. _YES_

a. the identification of the equipment being inspected;

Did the operator maintain inspection records that document the 

inspections of work practice standards for the monitoring equipment, that contain 

at a minimum the following:

b. the date, time, and identity of the inspection and inspector;

c. the working condition of the equipment; and

d. any actions taken to remedy any deficiencies found.
2. _N/A

a. the identification of the equipment that malfunctioned;

_ Did the operator maintain malfunction records that document the 

malfunctions that occurred on the monitoring equipment, that contain, at a 

minimum:

b. the date, duration, and cause of the malfunction; and

c. a brief description of the corrective action taken, if it is inconsistent with the 

O&M plan, including: occurrence, duration, and cause of any malfunction of the 

process, air pollution control device, and monitoring equipment.

3. _N/A_ If applicable, did the operator maintain copies of all performance test 

results on the operating parameters that were measured during the test?

4. _N/A_

a. the start and end times and dates of each period of excess emissions;

Did the operator maintain records of all excess emissions and document 

whether they were attributable to equipment malfunction, that at a minimum 

contain:

b. if caused by malfunction the: type of malfunction, duration of malfunction, cause 

of malfunction, corrective actions, and date and time of malfunction; and

c. the action taken to remedy the situation.

5. _YES Did the operator maintain records of the process operating time for each 

tank and the date and time of each addition of the wetting agent?

Please provide an explanation if any of the above records were not maintained:

6. Is the operator required by an order or other stationary source regulation of the Colorado 

Air Quality Control Commission to maintain any other records (circle one)?

Yes No

_____ If yes, were the records kept? Please explain the type of record and whether the 

records were properly maintained:

________________________________________________________________________

______

Please add any additional comments concerning this source and/or inspection as necessary.
Field Inspection Report for

Hard Chromium Electroplating Tank Using a Chemical Fume Suppressant

To fit within this category, the operator must demonstrate that a wetting agent is added to the 

hard chromium electroplating bath solution. A wetting agent is a fume suppressant that limits 

the emissions of chromium fumes by decreasing the surface tension of the bath. If there are any 

questions, please contact the Air Pollution Control Division at 692-3269.

A. Basic plating information:

1. What is the rectifier capacity of each of the tanks at this facility?

_TANK 501 – 1000 AMPS 

_____________________________________________________

_TANK 502 – 3000 AMPS 

______________________________________________________

_TANK 503 – 4000 AMPS 

_______________________________________________________

2. On what date was each electroplating tank(s) installed?

3. How are the tanks run or operated?

__ALL THREE TANKS WERE INSTALLED IN 1967 

______________________________

Is the same residence time used throughout the process

What are volts/amps for the process? 

? _DWELL TIME IS 

COMPLETELY DEPENDENT ON CUSTOMER SPEC (DESIRED THICKNESS) BUT 

CAN RANGE BETWEEN 15 MINUTES TO 1 HOUR. ___ 

___________

_____BETWEEN 4 AND 9 AMPS, BUT MOST 

OFTEN BETWEEN 6-7 AMPS. THIS FIGURE IS BASED ON 1 AMP PER SQUARE 

INCH OF SURFACE AREA TO BE PLATED. 
How does the company track operating time of the tank? 

Does the operator use an air sparge in the tank? If yes, please explain why and what you 

informed them about the use of an air sparge: 

__HOUR METERS AT EACH 

TANK.__ ___________________________________________

4. Other comments on operation and condition of the tanks (i.e., corrosion on tanks):

__USES AN AIR SPARGE ABOUT 

ONCE PER DAY TO AID IN MIXING. WE DISCUSSED WHAT MIGHT OCCUR IF 

THE SPARGE WAS LEFT IN THE TANK IN ONE 

SPOT._________________________________________

________________________________________________________________________

______

B. Reports: The operator must submit the following reports for hard chromium 

electroplating tanks using a wetting agent as an additive to U.S. EPA and the Division.

1. Did the operator make a change to the hard chromium electroplating process since 

February 24, 1997 (circle one)? Yes No

_____ If yes, did the operator submit a report within 30 days of the change that includes 

the following?

a. A description of the manner in which the process has been changed and the 

emission limit, if any, now applicable to the tank;

b. If a different emission limit applies, the applicable information required by this 

regulation for that emission limit (contact the APCD at 692-3269); and

c. The notification and reporting requirements that are required by this regulation for 

that type of process (contact the APCD at 692-3269).

If no for any of the reasons in a, b, or c, please explain below:

________________________________________________________________________

_____

2. Has the company installed a new chromium anodizing or electroplating tank or modified 

an existing tank after January 25, 1995 (circle one)? Yes No

_____ If yes, did the operator submit to the Division a notification of construction or 

reconstruction or process change? If no notification was submitted, please 

explain:

________________________________________________________________________

3. Has the company switched from the current hard chromium electroplating process to 

another type of plating process (e.g., from hard to decorative) (circle one)? Yes No

_____ If yes, did the operator submit to the Division a notification of a process change? 

If no notification was submitted, please explain:

________________________________________________________________________

4. _YES_

________________________________________________________________________

Has the operator developed ongoing compliance status reports that demonstrate 

ongoing compliance with Subpart N on an annual basis? If no, please explain:
5. Is the operator required by an order or other stationary source regulation of the Colorado 

Air Quality Control Commission to maintain any other records (circle one)?

Yes No

_____ If yes, were the records properly maintained? Please explain the type of record.

________________________________________________________________________

_____

C. Ongoing Compliance Monitoring: The operator must conduct ongoing compliance 

monitoring in the form of surface tension measurements technically correctly and often 

enough. This monitoring shows the Division that emissions from the source are 

continually below the standard set when the initial performance test was conducted. 

When an exceedance does occur it must be documented and kept on file at the facility.

1. What surface tension level was established during the initial performance test?_37_

Use that surface tension level to answer the following questions, where appropriate.

dynes/dscm.

2. What type of wetting agent does the facility use? Has the facility had any problems with 

the wetting agent (i.e., causes pitting, doesn’t cover entire surface)?

____FUMETROL 140 E. NO PROBLEMS NOTED. 

____________________________

3. How often does the facility add the wetting agent? When do the operators know wetting 

agent needs to be added?

______FUMETROL IS ADDED WHENEVER SURFACE TENSION REACHES 35 

DYNES/CM. HOW OFTEN DEPENDS ON PRODUCTION RATE AND WHETHER 

A LARGE JOB IS ANTICIPATED IN THE NEAR FUTURE.

4. How often does the facility measure the surface tension of each tank?

__EVERY 40 HOURS OF OPERATION AS DETERMINED BY THE HOUR 

METER. 

_YES_Did the operator measure and record the surface tension for the first 40 hours, 

once every 4 hours, and, if the surface tension is less than or equal to the standard 

set during the test, then,

_YES_Did the operator measure and record the surface tension for the next 40 hours, 

once every 8 hours, and, if the surface tension is less than or equal to the standard 

set during the test, then,

_YES_

If the operator failed to comply with the above monitoring schedule, please explain:

Did the operator measure and record the surface tension once every 40 hours and 

continue with this schedule?

________________________________________________________________________

______

Did the surface tension measurements at any time exceed the standard set during the test 

(circle one)? Yes No
Did the operator change the tank solution at any time (circle one)? Yes No

_____ If yes to either of the above questions, did the operator resume the original 

monitoring schedule described above?

If the operator did not resume the original sampling schedule, please explain:

________________________________________________________________________

______

5. Ask that the operator demonstrate the taking of a surface tension sample.

_YES_

________________________________________________________________________

______

Did he/she follow the correct procedure (i.e., thoroughly clean stalagmometer, 

correctly measure surface tension)? If no, please describe the deficiencies in the 

procedure used:

D. Emission Limits: The operator must meet the following emission limit for each tank 

using a hard chromium electroplating bath with a wetting agent as an additive. Based 

upon the surface tension set at the initial performance test and records maintained by the 

company:

1. _YES_Has the company maintained compliance with the emission limit of 0.03 mg/dscm 

if it is a small, existing tank with maximum rectifier capacity of less than 60 

million amperes-hours per year?

_N/A_ Has the company maintained compliance with the emission limit of 0.015 

mg/dscm if it is a small new tank with maximum rectifier capacity of less than 60 

million amperes-hours per year or large tank with maximum rectifier capacity of 

greater than 60 million amperes-hours per year?

2. YES_

_____ If no, did the operator record the excess emissions and maintain the record onsite?

Did the company maintain the surface tension at or below the standard set during 

the initial performance test since January 25, 1997 or the last inspection?

If the operator did not comply with the surface tension standard and/or failed to maintain 

excess emission records, please explain.

________________________________________________________________________

______

E. Operating and Maintenance Plan: The Operator must develop an Operation and 

Maintenance plan (O&M plan) and implement it no later than the stated implementation 

date. The O&M plan must incorporate work practice standards for any surface tension 

monitoring equipment as discussed above. The Operator must at all times including 

periods of startup, shutdown, and malfunctions, and operate and maintain any affected 

equipment consistent with the O&M plan. The Operator must ensure that the following 

is done.

1. Development of Operation and Maintenance Plan

_YES_Did the operator develop an Operation and Maintenance Plan?

_YES_

If no was answered to any of the above, please explain:

Was the operator able to provide you with a copy during the inspection?
________________________________________________________________________

______

2. Content of Operation and Maintenance Plan

_YES_

a. a description of the surface tension monitoring system(s) for the process and 

pollution control systems;

Upon review of the Operation and Maintenance Plan, did it meet the basic 

requirements described below?

b. a checklist to document the operation and maintenance done on the equipment;

c. a description of the operating procedures from the manufacturer; and

d. procedures to follow to ensure that equipment or process malfunctions due to poor 

maintenance or other preventable conditions do not occur.

_YES_

a. tank(s) and associated ductwork, and

Did the Operator operate and maintain the following according to the O&M plan:

b. air pollution monitoring equipment?

If no was answered to any of the above, please explain:

________________________________________________________________________

______

3. Were there any upsets or malfunctions involving the tanks (circle one)? Yes

No

_ _

_____ If the plan was not complied with, did the operator revise the plan?

If yes, did the Operation and Maintenance Plan address the malfunctions and 

corrections of malfunctions and did the operator comply with the plan during 

those periods?

If no to either of the above questions, please explain:

________________________________________________________________________

______

F. Recordkeeping: The operator must maintain the proper recordkeeping. The records 

must be made available to the Division, local inspectors, and U.S. EPA and maintained 

for at least 5 years.

1. _YES_

a. the identification of the equipment being inspected

Did the operator maintain inspection records that document the inspections of 

work practice standards for the monitoring equipment, that contain at a minimum 

the following:

b. the date, time, and identity of the inspection and inspector

c. the working condition of the equipment

d. any actions taken to remedy any deficiencies found

2. _N/A_

a. the identification of the equipment that malfunctioned,

Did the operator maintain malfunction records that document the malfunctions

that occurred on the monitoring equipment, that contain, at a minimum:

b. the date, duration, and cause of the malfunction, and

c. a brief description of the corrective action taken, if it is inconsistent with the 

O&M plan, including: occurrence, duration, and cause of any malfunction of the 

process, air pollution control device, and monitoring equipment?
3. _YES_If applicable, did the operator maintain copies of all performance test results on 

the operating parameters that were measured during the test?

4. _YES_

a. the start and end times and dates of each period of excess emissions,

Did the operator maintain records of all excess emissions and document whether 

they were attributable to equipment malfunction, that at a minimum contain:

b. if caused by malfunction the: type of malfunction, duration of malfunction, cause 

of malfunction, corrective actions, and date and time of malfunction, and

c. the action taken to remedy the situation?

5. _YES_Did the operator maintain records of the process operating time for each tank and 

the date and time of each addition of the wetting agent?

Please provide an explanation if any of the above records were not maintained:

______________________________________________________________________________

_____

6. Is the operator required by an order or other stationary source regulation of the Colorado 

Air Quality Control Commission to maintain any other records (circle one)?

Yes No

_____ If yes, were the proper records maintained?

If no, please explain the type of record(s) and the noncompliance issue:

________________________________________________________________________

______