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

T elephone 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

A ir 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 A dvisory

Compliance AdvisoryAIR 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 lar gely 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 requi rements 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. T here 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, ni ckle, 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, th ese 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

facil ity. 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 p lating 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 w etting 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 Chro mium 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. 43 RD AVE COUNTY:

DENVER

INSPECTOR: AMY S. WILEY

CONTACT PERSON: ANDY EBEN OR KERRY MORGAN

TELEPHONE NO.: 303

- 295

- 1380

CONSTRUCTION PERMIT NO.:

IS SUANCE 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, Subpart s 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 operate d? 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 c hange 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 w hich 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. Th e 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 reco nstruction 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 maintaine d? If no, please explain:

________________________________________________________________________

_____

C. Ongoing Compliance Monitoring: The operator must conduct ongoing compliance monitoring in the form of surface tension measurements technically corr ectly 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 fac ility 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 wettin g 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 equ al 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 surf ace tension once every 40 hours and

continue with this schedule?

________________________________________________________________________

______

Did the surface tension me asurements 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 descri bed 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 cle an stalagmometer, correctly measure surface tension)? If no, please describe the deficiencies in the procedure used:

D. Emission Limits: The operator must meet the following e mission 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 on

site? Did the company maintain the surface tension at or below 45 dynes/cm since January 25, 1996 or the l ast 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 inco rporate work practice standards for any surface tensionmonitoring 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 ba sic 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 mal functions 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 comp lied 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. Th e 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 equipme nt, 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 deficien cies 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 equipme nt.

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 acti ons, 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, we re 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 inspec tion 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 t he 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, no w 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 su bmitted, 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 opera tor 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 Divi sion 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 du ring 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., caus es 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 I S 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 D ETERMINED 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 mea sure 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 an d

continue with this schedule?

________________________________________________________________________

______ Did the surface tension measurements at any time exceed the s tandard set during the test (circle one)? Yes NoDid 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 op erator 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. Y ES_

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

site? 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 Operato r 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 Pl an _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 proces s 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 malfunction s 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 t o 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 add ress 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 lea st 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, i f 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 performan ce 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 reme dy 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:

________________________________________________________________________

______