DAQ-2024-004604

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DAQC-CI109870001-23
Site ID 10987 (B1)

MEMORANDUM

TO: FILE – ANODIZING & METAL COATINGS

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Jordan Garahana, Environmental Scientist

DATE: December 6, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor Non-AO, Salt Lake County

INSPECTION DATE: November 29, 2023

SOURCE LOCATION: 1163 South 2250 West
Salt Lake City, UT 84101
SOURCE CONTACTS: Krista Williams, Quality Control Manager
801-975-1132 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Chrome anodizing facility. Conducts various plating operations
including chromic acid anodizing for the aerospace industry. The
facility is categorized as a small existing area source with the
maximum potential capacity of 5,880,000 amp-hr/yr. The tank
has a rectifier capacity of 1000 amperes. A wetting agent is used
as the control device to maintain the surface tension at or below
40 dynes/cm. Vents above the tank rim pull emissions to the
atmosphere. Hexavalent, rather than trivalent, chrome is used.
According to the initial report, this chrome tank has been in use
since 1985. Other tanks on site contain a sulfuric acid base with
current for hard coating, rinse water, etc. Aerospace parts are
anodized in an electrochemical process that converts the metal
surface into a durable, corrosion-resistant, anodic oxide finish.
The parts are washed, cleaned, immersed in various electrolyte
baths, rinsed with deionized water, anodized, rinsed, sealed,
dried, wrapped, and shipped to customers. Anodizing occurs in a
900-gallon tank about (8 x 3.5) feet with electrodes on both long
sides. Parts are hung from a center copper bar cathode
(conductor) into the chromic acid bath (10 ounce per gallon at
105 degrees Fahrenheit)

APPLICABLE REGULATIONS:
MACT (Part 63) -N: National Emission Standards for Chromium
Emissions From Hard and Decorative Chromium Electroplating
and Chromium Anodizing Tanks, UAC R307-214

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Anodizing & Metal Coatings - Anodizing &
Metal Coatings

1163 South 2250 West 1163 South 2250 West
Salt Lake City, UT 84104 Salt Lake City, UT 84101

SIC Code: 3479: (Coating, Engraving, & Allied Services, NEC)

Section III: APPLICABLE FEDERAL REQUIREMENTS
MACT (Part 63) -N: National Emission Standards for Chromium Emissions From Hard and Decorative
Chromium Electroplating and Chromium Anodizing Tanks

40 CFR 63.342(a)

- (1) At all times, each owner or operator must operate and maintain any affected source subject to the
requirements of this subpart, including associated air pollution control equipment and monitoring equipment,
in a manner consistent with safety and good air pollution control practices for minimizing emissions. The
general duty to minimize emissions does not require the owner or operator to make any further efforts to
reduce emissions if levels required by this standard have been achieved. Determination of whether such
operation and maintenance procedures are being used will be based on information available to the
Administrator which may include, but is not limited to, monitoring results, review of operation and
maintenance procedures, review of operation and maintenance records, and inspection of the source.

Status: In Compliance. Source utilizes practices to minimize emissions from the operations.

40 CFR 63.342(d) Standards for chromium emissions control

- (1, 3) not allowing the surface tension of the electroplating or anodizing bath contained within the affected
tank to exceed 40 dynes/cm (2.8 x 10-3 lbf/ft), as measured by a stalagmometer

Status: In Compliance. The chrome bath is tested weekly every Wednesday. Records reviewed at the
time of inspection from November 2022, to November 2023, show that the surface tension never
exceeded 40 dynes/cm, with the highest total recorded at 37.1 dynes/cm in May 2023. The source
measures surface tension using a stalagmometer.

40 CFR 63.342(d)

- (4) No Perfluorooctane Sulfonic Acid (PFOS) fume suppressant can be added to tanks after 9/21/2015.

Status: In Compliance. The source uses Ankor Dyne 30 MS as a fume suppressant, which is a PFOS-free
substance.

40 CFR 63.342(f) Operations and Maintenance (O&M) practices

- (1) at all times, including startup, shutdown, and malfunction, operate and maintain the tank in a manner
consistent with good air pollution control practices. Malfunctions are to be corrected asap.

Status: In Compliance. No malfunctions or breakdowns have occurred since the previous inspection.

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40 CFR 63.342(f)(3)(i)

Facility shall have an operation and maintenance plan that specifies the O&M criteria, the control device used,
and monitoring equipment with a checklist to document the O&M of the equipment.

Status: The source maintains an O&M plan that is the same plan from the previous inspection. A copy
of the current O&M plan can be viewed in the 2022 inspection file (DAQC-319-22). The current O&M
plan was viewed onsite at the time of inspection.

40 CFR 63.342(f)(3)(i)(D);

- Plan specifies procedures to be followed to ensure that malfunctions due to poor maintenance

Status: In Compliance. The O&M plan contains procedures to check for proper surface tension and
cleaning once a month with nitric acid.

40 CFR 63.342(f)(3)(v)

- O&M Plan is kept and is available for the life of the affected source or until the source is no longer subject to
the regulations.

Status: In Compliance. The O&M plan keeps all previous versions of the O&M plan onsite for
recordkeeping and viewing for at least 5 years from the previous revision to the plan.

40 CFR 63.343(a) Compliance Dates and Type of Control.

(2) If the owner or operator of an affected source meets all of the following criteria, an initial performance test
is not required to be conducted under this subpart:
i. The affected source is a hard chromium electroplating tank, a decorative chromium electroplating tank
or a chromium anodizing tank; and
ii. A wetting agent is used in the plating or anodizing bath to inhibit chromium emissions from the
affected source;
iii. The owner or operator complies with the applicable surface tension limit of §63.342(c)(1)(iii),
(c)(2)(iii), or (d)(2) as demonstrated through the continuous compliance monitoring required by
paragraph (c)(5)(ii) of this section.

Status: In compliance. Anodizing Metal & Coatings uses a chromium anodizing tank with a fume
suppressant, and regularly monitors the dynes/cm of the suppressant, so an initial performance test is
not required.

40 CFR 63.343(a)(8)

Implement the housekeeping procedures from Table 2.

For You must: At this minimum frequency
Any substance used in an
affected chromium
electroplating or chromium
anodizing tank that contains
hexavalent chromium.
(a) Store the substance in a
closed container in an enclosed
storage area or building; AND
(b) Use a closed container
when transporting the
At all times, except when
transferring the substance to
and from the container.
Whenever transporting
substance, except when
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substance from the enclosed
storage area.
transferring the substance to
and from the container.
2. Each affected tank, to
minimize spills of bath solution
that result from dragout.
Note: this measure does not
require the return of
contaminated bath solution to
the tank. This requirement
applies only as the parts are
removed from the tank.
Once away from the tank area,
any spilled solution must be
handled in accordance with
Item 4 of these housekeeping
measures.
(a) Install drip trays that collect
and return to the tank any bath
solution that drips or drains
from parts as the parts are
removed from the tank; OR
(b) Contain and return to the
tank any bath solution that
drains or drips from parts as the
parts are removed from the
tank; OR
(c) Collect and treat in an
onsite wastewater treatment
plant any bath solution that
drains or drips from parts as the
parts are removed from the
tank.
Prior to operating the tank.
Whenever removing parts from
an affected tank.
Whenever removing parts from
an affected tank.

3. Each spraying operation for
removing excess chromic acid
from parts removed from, and
occurring over, an affected
tank.

Install a splash guard to
minimize overspray during
spraying operations and to
ensure that any hexavalent
chromium laden liquid
captured by the splash guard is
returned to the affected
chromium electroplating or
anodizing tank.
Prior to any such spraying
operation.

4. Each operation that involves
the handling or use of any
substance used in an affected
chromium electroplating or
chromium anodizing tank that
contains hexavalent chromium.
Begin clean up, or otherwise
contain, all spills of the
substance. Note: substances
that fall or flow into drip trays,
pans, sumps, or other
containment areas are not
considered spills.
Within 1 hour of the spill.

5. Surfaces within the enclosed
storage area, open floor area,
walkways around affected
tanks contaminated with
hexavalent chromium from an
affected chromium
electroplating or chromium
anodizing tank.
(a) Clean the surfaces using
one or more of the following
methods: HEPA vacuuming;
Hand-wiping with a damp
cloth; Wet mopping; Hose
down or rinse with potable
water that is collected in a
wastewater collection system;
At least once every 7 days if
one or more chromium
electroplating or chromium
anodizing tanks were used, or
at least after every 40 hours of
operating time of one or more
affection chromium
electroplating or chromium
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Other cleaning method
approved by the permitting
authority; OR
(b) Apply a non-toxic chemical
dust suppressant to the
surfaces.
anodizing tank, whichever is
later.
According to manufacturer’s
recommendations.
6. All buffing, grinding, or
polishing operations that are
located in the same room as
chromium electroplating or
chromium anodizing
operations.
Separate the operation from
any affected electroplating or
anodizing operation by
installing a physical barrier; the
barrier may take the form of
plastic strip curtains.
Prior to beginning the buffing,
grinding, or polishing
operation.

7. All chromium or chromium-
containing wastes generated
from housekeeping activities.

Store, dispose, recover, or
recycle the wastes using
practices that do not lead to
fugitive dust and in accordance
with hazardous waste
requirements.
At all times.

Status: In Compliance. The tank substance, when moved, is stored in a sealed steel can. The tank
includes drip trays that collect the bath solution waste. The waste is collected semi -annually and sent to
the city for disposal, with a yearly inspection conducted on the tank. The tank includes splash guards
and spills are cleaned within one hour of the spill occurring. Surfaces around the tank are cleaned with
potable water that is hosed around the area. No buffing, grinding, or polishing occur in the same room
as the bath. All waste associated with the chrome anodizing process is disposed of properly.

40 CFR 63.346(b)(1, 2, 13)

- Inspection records of all add on devices
- Maintenance records performed on relevant equipment
- Malfunctions on equipment (occurrence, duration, cause)
i. Actions taken during malfunction
ii. Records of any excess emissions during malfunction
- Total process operating time
- Record of fume suppressants used (0-e/time/product)
- Record of bath components purchased, identifying wetting agent

Status: In Compliance. The source tests the surface tension of the baths weekly and stores it for record
keeping in a logbook. No malfunctions or breakdowns have occurred since the previous inspection, so
there are no records of malfunctions viewed at the time of inspection. The fume suppressant is a
PFOS-free substance and is compliant with this rule. The total processing time is included in their
ongoing compliance statement. A copy of that statement can be viewed in the attachments section of this
memo.

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AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. Compliance with R307-214 is determined by compliance with applicable
federal subparts. In compliance with Subpart N.

40 CFR 63.346(c):

- The operator keeps the records to document compliance with the regulation for five years.

Status: In Compliance. All records have been maintained for the past 20 years.

40 CFR 63.347(c)(1)

The owner or operator of each affected source subject to these standards shall fulfill all reporting requirements
outlined in this section and in the General Provisions to 40 CFR part 63, according to the applicability of
subpart A as identified in Table 1 of this subpart. These reports shall be made to the Administrator at the
appropriate address as identified in §63.13 or to the delegated State authority.

Status: In Compliance. The source filed their initial notification as required as part of the 2004
inspection. That document can be found in the 2010 inspection memo (DAQC-138-10).

40 CFR 63.347(e)

Submit a compliance status report within 30 days of compliance date that includes:
i. Applicable emission limitation and methods used to determine compliance.
ii. Methods that will be used to determine continuous compliance.
iii. Description of the air pollution control technique for each emission point.
iv. Statement that the operator has the O&M plan completed and on file.
v. Statement by the operator as to whether the tank is in compliance with this regulation.

Status: In Compliance. The source filed their initial notification as required as part of the 2004
inspection. That document can be found in the 2010 inspection memo (DAQC-138-10). The original
statement included an applicable emission limit of 45 dynes/cm. The source maintains a completed
O&M plan on file.

40 CFR 63.347(h)

Prepares an ongoing compliance status report for area source. Submits ongoing compliance reports annually if
required or retains it on-site, and makes it available to inspector upon request.

Status: In Compliance. The source submits annual ongoing compliance reports, with the most recent
report being submitted on October 2, 2023, for the timeframe of October 2022-October 2023. See the
attachments section for additional information about the ongoing compliance statement, as well as
information about the weekly surface tension readings.

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EMISSION INVENTORY:
No Emission Inventory has been requested or required for this source. No potential to emit has been
calculated for this source.

Criteria Pollutant PTE tons/yr

Hazardous Air Pollutant PTE lbs/yr

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In Compliance with conditions listed in Subpart N. The facility
appears to be well maintained and records were made available
upon request.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at the usual frequency.

ATTACHMENTS: Applicable supporting documentation included