Howard Finishing, LLC (Howard Finishing) owns and operates a plating facility at 15765 Sturgeon Street, Roseville, Michigan, where it conducts, among other things, nickel electroplating. The U.S. Environmental Protection Agency issued a Finding of Violation to Howard Finishing on August 30, 2012, for violating Section 112 of the Clean Air Act, 42 U.S.C. ? 7412; and the implementing regulations at 40 C.F.R. Part 63, Subpart WWWWWW, the National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations (Subpart WWWWWW) Specifically, Howard Finishing failed to control emissions from a microporous nickel tank at the facility in accordance with Subpart WWWWWW. The U.S. Environmental Protection Agency discovered these violations while inspecting the facility on May 6, 2010, and issued a Finding of Violation to Howard Finishing on August 30, 2012.
With regard to the microporous nickel tank, Subpart WWWWWW requires Howard Finishing to control emissions from it by doing one of the following: 1) using a wetting agent/fume suppressant (WA/FS) in the bath of the tank; 2) capturing and exhausting emissions from the tank to a composite mesh pad, a packed-bed scrubber, or a mesh pad mist eliminator; or 3) covering the surface of the tank. Subpart WWWWWW requires that those sources that choose to use a WA/FS in the bath of their affected tanks must add the WA/FS in the amounts recommended by the manufacturer for that specific type of