Hydro-Platers owns and operates a metal-plating facility where it conducts hard-chromium electroplating, sulfamate-nickel electroplating, and nickel electroless plating. The facility consists of six open-surface hard chromium-electroplating tanks subject to Subpart N. Emissions from Tanks 1, 2, and 3 vent to a common packed-bed scrubber (System 1), and Tanks 4, 5, and 6 vent to their own similar system (System 2).
Specifically, Hydro-Platers failed to:
(1) demonstrate initial compliance by not conducting the initial performance test on or before March 19, 2015, required by Subpart N;
(2) maintain the emission limit of 0.011 milligrams of total chromium per dry standard cubic meter (mg/dscm) of ventilation air for all open surface hard chromium electroplating tanks of System 1;
(3) properly monitor and record the pressure drop across all stages of Systems 1 and 2;
(4) maintain certain records and prepare all reports required under Subpart N;
(5) include its dry mechanical polishing machines in the reports it submitted to EPA required under Subpart WWWWWW; and
(6) prepare annual compliance certifications for Subpart WWWWWW.
In order to achieve compliance, Hydro-Platers:
(1) upgraded its monitors to allow for automatic recording of the pressure drop across the packed-bed systems;
(2) conducted performance tests of its systems between January 26, 2016 and May 19, 2016 to establish the pressure drop across each system;
(3) trained its employees on how t