DAQ-2024-004362

1
DAQC-1373-23
Site ID 10976 (B1)

MEMORANDUM

TO: FILE – OGDEN CHROME

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: December 27, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, MINOR NON-AO, WEBER COUNTY

INSPECTION DATE: December 7, 2023

SOURCE LOCATION: 124 18th Street, Ogden, Utah 84401

SOURCE CONTACT(S): Jose Rubi: 801-317-6093

OPERATING STATUS: Operating normally at the time of inspection. The chrome tank
was operational but not in use.

PROCESS DESCRIPTION: Decorative chrome plating shop.

APPLICABLE REGULATIONS: 40 CFR Part 63 Subpart N, National Emission Standard for
Chromium Emissions From Hard and Decorative Chromium
Electroplating and Chromium Anodizing Tanks, UAC
R307-214-2, Sources subject to Part 63

SOURCE EVALUATION:

63.340 Applicability

Status: In compliance. The source is a decorative chromium electroplating facility.

63.342(d) Standards (only regulations applicable to decorative chrome electroplating are addressed)

(d)(1, 3 & 4) not allow concentration of total chromium in exhaust stream discharged to atmosphere to
exceed 0.007 mg/dscm (existing) or if chemical fume suppressant used, the surface tension < or = 40
dynes/cm measured by stalagmometer or the surface tension < or = 33 dynes/cm measured by a
tensiometer or after 9/21/15 no PFOS-based fume suppressants added (perfluoro octane sulfonic acid).

Status: In compliance. Stalagmometer indicated 23.9 dynes/cm. The source sends their sample to
Western Analytical Labs for testing. The last measurement was conducted on September 29, 2023.
The fume suppressant ANKOR Dyne 30 MS does not contain any PFOS. See the attachments
section for additional information.

2
63.342 (f) Operation and Maintenance

(f)(1)(i & ii) operate with good air pollution practices & fix malfunctions as soon as possible.

Status: In compliance. The chrome plating operations have had low surface tension measurements
for several years. When the surface tension reaches 30 dynes/cm the fume suppressant ANKOR
Dyne 30 MS is added.

(f)(2 & 3) revisions and O & M plan

Status: In compliance. The current plan is dated November 15, 2008, with an addendum dated
March 6, 2019. Tensiometer or stalagmometer is the standard control for surface tension. The
O&M plan includes the following: control, standardize checklist, malfunctions, and housekeeping
(Table 2) (compliance date March 19, 2013 – 63.343(a)(8)). A copy of this O&M plan was viewed
onsite at the time of inspection and can be found in the attachments section.

63.343 Compliance provisions

(a) compliance date for existing source in no later than 9/21/14

Status: In compliance. The source samples or sends samples to Western Analytical Laboratory to
be tested.

(c)(5) wetting agent fume suppressant – site specific operating parameter surface tension – or comply
with the 33 dynes/cm limit as measured with the tensiometer.

Status: In compliance. The source measures the surface tension by sampling the chrome bath and
sending the sample to a laboratory. The current surface tension was measured on September 29,
2023, at 23.9 dynes/cm.

63.346 Recordkeeping requirements

(b)(1-16) maintenance, malfunctions, operating process time, fume suppressants added and how much,
bath components purchased, all notifications

Status: In compliance. The last fume suppressant added to the tank was 1 quart on December 15,
2023. No malfunctions or maintenance have occurred since the last inspection.

63.347 Reporting requirements

(c) initial notifications

Status: In compliance. All requirements were met in the initial notification.

(e) notification of compliance status

Status: In compliance. All requirements were met in the compliance status notification.

3
(g)(3) ongoing compliance status report

Status: In compliance. Operating time is recorded on a monthly basis. The operating time for 2022
(reporting period is January 1- December 31, 2022), indicated 21.2 hours with an applicable
emission limit of less than 40 dynes/cm. The ongoing compliance sheet was viewed at the time of
inspection.

AREA SOURCE
REGULATIONS: R307-214 is applicable since the source is subject to Subpart N
within 40 CFR Part 63. Compliance with R307-214 is
determined by compliance with Subpart N.

EMISSION INVENTORY: No emission inventory has been requested to date and no
potential to emit has been calculated for the source.

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions have been noted for the past 5 years.

COMPLIANCE STATUS & In Compliance. No further action is required.
RECOMMENDATIONS:

RECOMMENDATION FOR Inspect as usual.
NEXT INSPECTION:

ATTACHMENTS: VEO form, daily log, surface tension log, and correspondence

12/27/23, 3:18 PM State of Utah Mail - Ogden Chrome
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1785732911011501721&simpl=msg-f:178573291101150172…1/2
Jordan Garahana <[e-mail]>
Ogden Chrome
3 messages
Jose Rubi <[e-mail]>Tue, Dec 19, 2023 at 10:40 AM
To: "[e-mail]" <[e-mail]>
Hello, here is the email with the stuff you needed let me know if I’m missing anything else.
2 attachments
Start Date.pdf
635K
WESTERN.pdf
2546K
Jordan Garahana <[e-mail]>Tue, Dec 19, 2023 at 10:47 AM
To: Jose Rubi <[e-mail]>
Hey Jose,
Thank you for sending the information I requested over to me. I will let you know if I have any other questions or
documents I need to complete my inspection. Thanks and have a happy holiday!
Thanks,
Jordan Garahana
On Tue, Dec 19, 2023 at 10:40 AM Jose Rubi <[e-mail]> wrote:
Hello, here is the email with the stuff you needed let me know if I’m missing anything else.
--
Jordan Garahana
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
12/27/23, 3:18 PM State of Utah Mail - Ogden Chrome
https://mail.google.com/mail/u/0/?ik=038c40f7b3&view=pt&search=all&permthid=thread-f:1785732911011501721&simpl=msg-f:178573291101150172…2/2
Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
Jose Rubi <[e-mail]>Tue, Dec 19, 2023 at 10:48 AM
To: Jordan Garahana <[e-mail]>
Awesome thanks again man, and yeah let me know if you need anything else. I’ll be gone all next week but will be back at
the begging of the year! You have a great Christmas and new years!
Jose Rubi
General Manager/Production Manager
Ogden Chrome
800.453.3007
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