HomeMy WebLinkAboutDAQ-2024-0043711
DAQC-1365-23
Site ID 12312 (B1)
MEMORANDUM
TO: FILE – AEROSPACE ENGINEERING & SUPPORT INC.
THROUGH: Chad Gilgen, Minor Source Compliance Manager
FROM: Jordan Garahana, Environmental Scientist
DATE: December 21, 2023
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, NESHAP, Weber County
INSPECTION DATE: December 7, 2023
SOURCE LOCATION: 1307 West 2550 South
Ogden, UT 84401
SOURCE CONTACT(S): Hayden Oram – Plating Manager
801-621-6805 hayden.o@fourpinescoating.com
Rusty Oram – Owner
801-394-9565 rusty.o@fourpinescoating.com
OPERATING STATUS: Chromic anodizing tank was operational but not in use at the time of
inspection.
PROCESS DESCRIPTION: Four Pines Coating (Aerospace Engineering & Support Incorporated is
no longer associated with the manufacturing and chromic anodizing of
airplane parts), manufactures and chromic anodizes airplane parts. The
source operates a 220-gallon chromic anodizing tank. Airplane parts are
chromic anodized in the anodizing tank containing a solution of 6.7 to
13.4 oz. of chromic acid per 1 gallon of water. The anodizing solution
temperature is maintained at 90 to 100 F, with an electrical voltage of 40
volts. The source complies with the current requirement of under 40
dynes/cm of surface tension for emission control. The surfactant utilized
is Triton X-100. No other control equipment is utilized for the chromic
anodizing tank. Parts to be chromic anodized are left in the tank for 40
minutes. Monitoring the tanks surface tension is done every 40 hours.
Monitoring records of the anodizing tanks’ surface tension dates back to
January 5, 1998. Stack testing is not required at his source. Records
required by NESHAP 63.340 through 63.346 Subpart N (Chromic
Anodizing) were made available and were reviewed during the
inspection.
APPLICABLE
REGULATIONS: National Emission Standards for Hazardous Air Pollutants (NESHAP)
63.340 through 63.346 Subpart N (Chromic Anodizing) revised
September 19, 2012 (77 FR 58220). This operation was determined in
1998 by the DAQ to be under the permitting limits which would require
an AO.
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SOURCE INSPECTION
EVALUATION: Conditions of NESHAP Subpart N Chromic Anodizing.
63.340 Applicability and designation of sources
(a) The affected source to which the provisions of this subpart apply is each chromium electroplating or
chromium anodizing tank at facilities performing hard chromium electroplating, decorative chromium
electroplating, or chromium anodizing.
Status: Applicable. The source operates a 220-gallon chrome anodizing tank.
(b) Owners or operators of affected sources subject to the provisions of this subpart must also comply
with the requirements of subpart A of this part, according to the applicability of subpart A of this part to
such sources, as identified in Table 1 of this subpart.
Status: In compliance. A stalagmometer and a capillary tube are both utilized to comply
with Method 306B.
63.342 Standards
(a) Each owner or operator of an affected source subject to the provisions of this subpart shall comply
with these requirements on and after the compliance dated specified in Section 63.343(a). All affected
sources are regulated by applying maximum achievable control technology.
Status: In compliance. The chrome anodizing process has a reported start-up date of
January 1, 1985. The source was found in compliance on January 25, 1997.
(b) Applicability of emission limits.
(b)(1) The emission limitations in this section apply only during tank operation, and also apply during
periods of startup and shutdown as these are routine occurrences for affected sources subject to this
subpart. The emission limitations do not apply during periods of malfunctions, but the work practice
standards that address operation and maintenance (O&M) and that are required by paragraph (f) of this
section must be followed during malfunctions.
Status: In compliance. Surface tension is tested every 40 hours of use. Records are
maintained in the office and were viewed at the time of inspection with all 40-hour
required readings being below 40 dynes/cm. The latest surface tension reading was
conducted on June 12, 2023, and was measured at 40 dynes/cm. No malfunctions or
excess emissions have occurred. The tank is installed inside an enclosure barrier
that prevents contamination of outside areas and is equipped with a fume hood.
(d)(3) if a chemical fume suppressant containing a wetting agent is used, by not allowing the surface
tension of the electroplating or anodizing bath contained within the affected source to exceed 40 dynes
/cm or 33 dynes/cm as measured by a tensiometer, at any time during operation of the tank.
Status: The chemical fume suppressant utilized in the anodizing tank is Triton X-100
surfactant. Triton X-100 is PFOS-free.
(d)(4) After 9/21/15 owner/operator shall not add PFOS-based fume suppressants to any anodizing tanks.
Status: In compliance. Triton X-100 is the only surfactant used and this product does not
contain any PFOS.
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(f) O&M practice standards. All owners or operators subject to the standards in paragraphs (c) and (d) of
this section are subject to these work practice standards.
(f)(1)(i) at all times, including periods of startup, shutdown, and malfunction, owners or operators shall
operate and maintain any affected source, including associated air pollution control devices and
monitoring equipment in a manner consistent with good air pollution control practices, consistent with the
O&M plan.
Status: In compliance. The chromic anodizing bath is maintained below 40 dynes/cm.
(f)(1)(ii) malfunctions shall be corrected as soon as possible after their occurrence in accordance with the
O&M plan.
Status: Not applicable. No malfunctions have occurred since startup.
(f)(1)(iii) O&M requirements established pursuant to section 112 of the Act are enforceable independent
of emissions limitations or other requirements in relevant standards.
Status: In compliance. The O&M procedures are adhered to by the source.
(f)(2)(i) determination of whether acceptable O&M 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 the O&M plan, procedures, and records, and inspection of the source.
Status: In compliance. The O&M plan meets the requirements of NESHAP regulations. The
plan is specific for the source and includes maintenance procedures such as adding
surfactant when needed and appropriate temperature controls.
(f)(2)(ii) based on the results of a determination made, the Administrator may require that an owner or
operator make changes to the O&M plan.
Status: In compliance. A revised O&M was issued in response to changes to 40 CFR 63,
Subpart N. The most recent O&M plan is dated January 25, 2023, which is the same
as the April 2016 plan, just changed in name to Four Pines Coating from Aerospace
Engineering & Support. This new plan was viewed onsite.
(f)(3) O&M plan
(f)(3)(i) owner or operator of an affected source subject to the work practices of paragraph (f) of this
section shall prepare an O&M plan to be implemented no later than the compliance date. The plan shall
be incorporated by reference into the source’s title V permit and shall include the following elements:
(f)(3)(i)(A) the plan shall specify the O&M criteria for the affected source, the add-on air pollution
control device, and the process and control system monitoring equipment, and shall include a
standardized checklist to document the O&M of this equipment.
Status: In compliance. A checklist is utilized to record the surface tension. Surfactant
information is included in the checklist. All information is maintained in the office
and was viewed at the time of inspection.
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(f)(3)(i)(B) for sources using an add-on air pollution control device or monitoring equipment to comply
with this subpart, the plan shall incorporate the work practice standards for that device or monitoring
equipment, as identified in Table 1 of this section.
Status: In compliance. The O&M plan includes the stalagmometer method and procedures,
and instructions to add surfactant when the surface tension increases.
(f)(3)(i)(D) the plan shall specify procedures to be followed to ensure that equipment or process
malfunctions due to poor maintenance or other preventable conditions do not occur.
Status: In compliance. Checklists and recordkeeping requirements ensure that preventable
conditions do not occur. No malfunctions have been recorded since January 5, 1998.
(f)(3)(i)(E) the plan shall include a systematic procedure for identifying the malfunctions or process
equipment, add-on air pollution control devices, and process and control system monitoring equipment
and for implementing corrective actions to address such malfunctions.
Status: In compliance. Checklists are utilized to ensure the surface tension is maintained
below 40 dynes/cm.
(f)(3)(i)(F) plan shall include housekeeping procedures as listed in Table 2
Status: In compliance.
(f)(3)(ii) if the O&M plan fails to address or inadequately addresses an event that meets the characteristics
of a malfunction at the time the plan is initially developed, the owner or operator shall revise the O&M
plan within 45 days after such an event occurs.
Status: In compliance. There have been no malfunctions requiring O&M plan revisions.
(f)(3)(iii) recordkeeping associated with the O&M plan is identified in Section 63.346(b). Reporting
associated with the O&M plan is identified in Section 63.347(g) and (h) and paragraph (f)(3)(iv) of this
section.
Status: In compliance. Record keeping is required by the O&M. Records are on site and are
back to the startup of operations at this location.
(f)(3)(v) the owner or operator shall keep the written O&M plan on record after it is developed to be made
available for inspection, upon request, by the Administrator for the life of the affected source or until the
source is no longer subject to the provisions of this subpart. Previous version of the O&M plan must be
kept for a period of 5 years.
Status: In compliance. The updated January 25, 2023, and the earlier April 2016, and
January 1995, O&M plans are kept on site. The current record keeping procedure
is to maintain all records on site indefinitely.
(f)(3)(vi) to satisfy the requirements of paragraph (f)(3) of this section, the owner or operator may use
applicable SOP manuals, OSHA plans, or other existing plans, provided the alternative plans meet the
requirements of this section.
Status: In compliance. This operation complies with company issued operating manuals and
OSHA plans in addition to the O&M.
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63.343 Compliance provisions
(a)(1) owner or operator of an existing affected source shall comply with the emission limitations in
63.342 by 9/19/14.
Status: In compliance. Previous inspections have confirmed that the source was compliant
upon startup of chrome anodizing operations which was May 5, 1998.
(b)(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.
(b)(2)(i) the affected source is a decorative chromium electroplating tank or a chromium anodizing tank,
and
(b)(2)(ii) a wetting agent is used in the plating or anodizing bath to inhibit chromium emission from the
affected source, and
(b)(2)(iii) owner or operator complies with the applicable surface tension limit of Section 63.342(d)(2) as
demonstrated through the continuous compliance monitoring required by paragraph (c)(5)(ii) of this
section.
Status: In compliance. The source has an anodizing chromic tank which uses Triton X-100
surfactant as a wetting agent and maintains a surface tension under 40 dynes/cm.
(c)(5)(i) monitoring to demonstrate continuous compliance. Wetting agent-type or combination wetting
agent-type/foam blanket fume suppressant. During the initial performance test, the owner or operator of
an affected source complying with the emission limits in Section 63.342 through the use of a wetting
agent in the electroplating or anodizing bath shall determine the outlet chromium concentration using the
procedures in Section 63.344(c). The owner or operator shall determine site-specific operating parameters
such as the surface tension using Method 306B, App. A of this part, setting the maximum value that
corresponds to compliance with the applicable emission limitation. The owner or operator may accept 40
dynes/cm.
Status: In compliance. A stalagmometer and a capillary tube (equivalent method) are
utilized to determine the surface tension of the chromic bath.
(c)(5)(ii) on and after the dated of the initial performance test, the owner or operator of an affected source
shall monitor the surface tension of the electroplating or anodizing bath. The surface tension shall be
monitored with a stalagmometer 40 dynes/cm or a tensiometer 33 dynes/cm – if over measure every 4
hours.
Status: In compliance. The surface tension was initially measured every 4 hours.
(c)(5)(ii)(B) the time between monitoring can be increased if there have been no exceedances. The surface
tension shall be measured once every 4 hours of tank operation for the first 40 hours of tank operation
after the compliance date. Once there are no exceedances during 40 hours of tank operation, surface
tension measurement may be conducted once every 40 hours of tanks operation on an ongoing basis, until
an exceedance occurs.
Status: In compliance. The surface tension was initially measured in accordance with this
requirement but is now subject to the requirement to test every 40 hours of use. The
source confirmed they operate in accordance with this requirement and maintain
the appropriate records.
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63.344 Performance test requirements and test methods:
(c) Test methods - Each owner or operator subject to the provisions of this subpart and required by
Section 63.343(b) to conduct an initial performance test shall use the test methods identified in this
section to demonstrate compliance with Section 63.342.
(c)(3) Method 306B, Surface Tension Measurement and Recordkeeping.
Status: In compliance. The source has been conducting Method 306B since January 25,
1997.
(d)(1) establishing site-specific operating parameter values - each owner or operator required to establish
site-specific operating parameter shall follow the procedures in this section.
Status: In compliance. The source follows the procedures as required.
(d)(3) surface tension of electroplating and anodizing baths shall be measured using Method 306B.
Status: In compliance. The source utilizes Method 306B to measure surface tension.
63.345 Provisions for new and reconstructed sources:
(a) this section identifies the preconstruction review requirement for new and reconstructed affected
sources that are subject to or become subject to this subpart (new is after 2/8/12).
Status: Not applicable, the source is categorized as an existing source since start-up date on
May 5, 1998.
63.346 Recordkeeping requirements:
(a) owner or operator of each source shall fulfill all recordkeeping requirements outlined in this section
and in the General Provisions to 40 CFR part 63, according to the applicability of subpart A of this part as
identified in Table 1 of this subpart.
Status: In compliance, Method 306B records of the surface tension have been maintained
since January of 1998.
(b) owner or operator shall maintain the following records:
(b)(1) inspection records for the add-on air pollution control device, if such a device is used, and
monitoring equipment to document that the inspection and maintenance required by the work practice
standards of Section 63.342(f) and Table 1 of Section 63.342 have taken place. The record can take the
form of a checklist and should identify the device inspected, the date of inspection, brief description of
the working condition of the device during the inspection, and any actions taken to correct deficiencies
found during the inspection.
Status: In compliance. The dates of surface tension testing measured in dynes/cm are
maintained at the source location.
(b)(2) records of all maintenance performed on the source, monitoring equipment.
Status: In compliance. Surfactant is added as required and records are maintained.
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(b)(6) test reports documenting results of all performance tests.
Status: In compliance. Records of the initial surfactant testing are consistent with the
NESHAP requirements.
(b)(8) records of monitoring data required by Section 63.343(c) that are used to demonstrate compliance
with the standard including the date and time the data are collected.
Status: In compliance. Time and surface tension were recorded.
(b)(11) total process operating time of the affected source during the reporting period.
Status: In compliance. The total operating time during the May 2022, through May 2023,
reporting period was 41 hours.
(b)(13) for sources using fume suppressants to comply, record the date and time that fume suppressants
are added to the electroplating or anodizing bath.
Status: In compliance. Time, date, and the amount of surfactant are included in the record.
(b)(16) all documentation supporting the notifications and reports required by Section 63.9, 63.10, and
63.347.
Status: In compliance. The construction notification was submitted on August 25, 1997.
(c) all records shall be maintained for a period of 5 years.
Status: In compliance. Records have been maintained since the start-up on May 5, 1998.
63.347 Reporting requirements:
(a) owner or operator of each affected source subject to these requirements outlined in this section and in
the General Provisions to 40 CFR part 63. These reports shall be made to the delegated State authority.
(a)(1) reports required by subpart A of this part and this section may be sent by US mail, fax or by another
courier.
Status: In compliance. The construction report was submitted by US mail.
(a)(1)(i) submittals sent by US mail shall be postmarked on or before the specified date.
Status: Construction notification report was submitted August 25, 1997. The source
commenced construction on June 6, 1997.
(b) reporting requirements of this section apply to the owner or operator of an affected source when such
source become subject to the provision of this subpart.
Status: Applicable. The source is subject to the provisions of this subpart.
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(c)(1) initial notifications - owner or operator that has an initial startup before January 25, 1995, shall
notify the Administrator in writing that the source is subject to this subpart. The notification shall be
submitted no later than 180 calendar days after January 25, 1995, and shall contain the following
information:
Status: Initial notification was submitted on September 13, 1999.
(c)(2) owner or operator of a new or reconstructed affected source that has an initial startup after January
25, 1995, shall submit an initial notification as follows:
(c)(2)(i) notification of the date when construction or reconstruction was commenced, shall be submitted
simultaneously with the notification of construction or reconstruction if it commenced before January 25,
1995.
Status: Initial notification was submitted on September 13, 1999.
(c)(2)(ii) notification of the date when the construction or reconstruction was commenced shall be
submitted no later than 30 calendar days after such date., if it commenced after January 25, 1995.
Status: Construction notification report was submitted August 25, 1997. The source
commenced construction on June 6, 1997.
(c)(2)(iii) notification of the actual date of startup of the source shall be submitted within 30 calendar days
after such date.
Status: Construction notification report was submitted August 25, 1997. The source
commenced construction on June 6, 1997.
(e)(1) notification of compliance status - notification of compliance status is required each time that an
affected source becomes subject to the requirements of this subpart.
Status: In compliance. Initial notification of compliance status was submitted on May 6,
1998.
(e)(2)(i) applicable emission limitation and the methods that were used to determine compliance with this
limitation.
Status: In compliance. The source complies with the <40 dynes/cm emission limit.
(e)(2)(iii) type and quantity of hazardous air pollutants emitted by the source reported in mg/dscm or
mg/hr if the source is using the special provisions of Section 63.344(e) to comply with the standards. For
sources not required to conduct a performance test in accordance with Section 63.343(b), the surface
tension measurement may fulfill this requirement.
Status: In compliance. The surface tension measured during startup was under the then
existing limit of 40 dynes/cm.
(e)(2)(iv) for each monitored parameter for which a compliance value is to be established under Section
63.343(c), the specific operating parameter value or range of values that corresponds to compliance with
the applicable emission limit.
Status: In compliance. The surface tension measured during startup was under the then
existing limit of 40 dynes/cm.
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(e)(2)(vi) description of the air pollution control technique for each emission point.
Status: In compliance. Method 306B will be utilized to monitor surface tension.
(e)(2)(vii) statement that the owner or operator has completed and has on file the O&M plan.
Status: In compliance. The initial statement was signed on May 6, 1998.
(e)(2)(ix) statement by the owner or operator as to whether the source has complied with the provisions of
this subpart.
Status: In compliance. The initial statement was signed on May 5, 1998.
(e)(4) for sources that are not required to complete a performance test, the notification of compliance
status shall be submitted to the Administrator no later than 30 days after the compliance date specified in
Section 63.343(a).
Status: In compliance, the start-up of the source was May 5, 1998, and the compliance
report was submitted on May 5, 1998.
(g)(3)(ii) identification of the operating parameter that is monitored for compliance determination as
required by Section 63.343(c).
Status: In compliance. The dynes/cm emission limit was listed.
(g)(3)(iii) relevant emission limitation for the source and the operating parameter value, or range of values
that correspond to compliance with this emission limitation as specified in the notification of compliance
status required by paragraph (e) of this section.
Status: In compliance.
(g)(3)(iv) beginning and ending dates of the reporting period.
Status: In compliance. The source uses May to May as the reporting period for hours of
operation.
(g)(3)(v) description of the type of process performed in the affected source.
Status: In compliance. Chrome anodizing is conducted.
(g)(3)(vi) total operating time of the affected source during the reporting period.
Status: In compliance. The chrome anodizing tank total operating time during the May
2022, through May 2023, reporting period was 41 hours.
(g)(3)(viii) summary of operating parameter values including the total duration of excess emissions
during reporting period as indicated by those values, the total duration of excess emissions expressed as a
percent of the total source operating time during that reporting period, and a breakdown of the total
duration of excess emissions during the reporting period into those that are due to process upsets, control
equipment malfunctions, other known causes, and unknown causes.
Status: In compliance. No excess emissions or malfunctions have occurred since the start-up
date of May 5, 1998.
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(g)(3)(ix) certification by a responsible official, that the work practice standard in Section 63.342(f) were
followed in accordance with the O&M plan.
Status: In compliance. The certification was signed by a responsible official at the source
location.
(g)(3)(xi) description of any changes in monitoring, processes, or control since the last reporting period.
Status: Not applicable. No changes have occurred since last reporting period.
(g)(3)(xii) name, title, and signature of the responsible official who is certifying the accuracy of the
report.
Status: In compliance. A responsible official signed the report.
(g)(3)(xiii) date of the report.
Status: In compliance. The report is dated May 19, 2017. No new reports have been
required.
(h)(1) ongoing compliance status reports for area sources - owner or operator of an affected source that is
located at an area source site shall prepare a summary report to document the ongoing compliance status
of the source. The report shall contain the information identified in paragraph (g)(3) of this section, shall
be completed annually and retained on site, and made available to the Administrator upon request. The
report shall be completed annually except as provided in paragraph (h)(2) of this section.
Status: In compliance. Refer to the above section (g)(3).
(h)(2)(i) reports of exceedances - if both of the following conditions are met, semiannual reports shall be
prepared and submitted to the Administrator.
(h)(2)(i)A) total duration of excess emissions is 1% or > of the total operating time for the reporting
period.
Status: Not applicable. No exceedances have occurred since start-up.
EMISSION INVENTORY: No emission inventories have been required for this source.
PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions in the last 5 years.
COMPLIANCE STATUS &
RECOMMENDATIONS: In compliance with all applicable provisions and sections of 40
CFR Part 63 Subpart N. The facility appears to be well
maintained and operated. Required records are current and were
viewed at the time of inspection.
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RECOMMENDATION FOR
NEXT INSPECTION: Inspect as normal. Aerospace Engineering & Support are no
longer affiliated with the chrome tanks and process associated
with this subpart. All the equipment associated with this
inspection going forward is under the name Four Pines Coating,
which is on the same property as Aerospace Engineering &
Support but is on the backside of the lot.
ATTACHMENTS: Chromic Anodizing Tank Monitoring Data Form