Document JogEn1gvXY9eYGOmpnbjQbNZ

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Advanced Plating Technologies, Milwaukee, WI Brittany Cobb AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Advanced Plating Technologies Facility Location: 405 W Cherry St, Milwaukee, WI 53212 Date of Inspection: 3/16/2022 EPA Inspector(s): 1. Brittany Cobb, Environmental Engineer 2. Emma Leeds, Environmental Engineer 3. Laura Steel, Environmental Engineer Intern Other Attendees: 1. John Lindstedt, CEO 2. Erik Probasco, Plant Manager 3. John Tinder, Environmental Manager 4. Tim Perry, Production Manager 5. Dre Hatch, Maintenance Manager Contact Email Address: johnl@advancedplatingtech.com and erikp@advancedplatingtech.com Purpose of Inspection: Determine compliance with the Clean Air Act Facility Type: Electroplating Facility Regulations Central to Inspection: 40 CFR Part 63 Subpart WWWWWW - National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations Arrival Time: 11:30 AM Departure Time: 1:30 PM Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: provided via email Provided CBI warning to facility The following information was obtained verbally from employees of Advanced Plating Technologies unless otherwise noted. Process Description: Advanced Plating Technologies (Advanced Plating or facility) performs the following electroplating: nickel, lead, gold, tin, silver, and copper. Advanced Plating also performs electroless plating, powder coating and vapor degreasing services and has numerous rinse and pretreatment tanks. The facility has rack plating and barrel plating lines for different products depending on their size and customer requirements. The 13 electrolytic nickel tanks (plus an additional tank that is nonoperational) and the 5 electrolytic lead tanks are subject to 40 CFR Part 63 Subpart WWWWWW. Advanced Plating controls emissions from the nickel and lead tanks with monthly additions of wetting agents. The facility also takes monthly qualitative measurements of surface tension using a wire with a loop in it. According to Erik Probasco, the facility dips the wire into the tanks and if the bubble that forms is less than half the size of the loop, then the surface tension is too high, and they add more wetting agent. Staff Interview: Advanced Plating has 65 employees, and the hours of operation are Monday through Friday 5:30 AM to 10:00 PM. Approximately 6 years ago one of the nickel tanks was replaced. The facility treats all waste from the tanks on site. The facility has an air permit with the Wisconsin DNR. Advanced Plating has two buildings where electroplating is performed, one at 405 W Cherry St and another at 428 W Vliet St. The facility reported emissions from each building separately. Page 2 of 5 There is a discrepancy between the reported emission, which Advanced Plating attributed to the fact that they are actually reporting all emissions together now. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA was led on a tour of the facility by John Lindstedt and Erik Probasco. There was about 660 pounds of cyanide in a powder form on site, Advanced Plating uses about 440 pounds per month. EPA examined the wetting agents used in the nickel and lead tanks (IMG_1416.JPG, IMG_1417.JPG and IMG_1418.JPG). EPA looked at the following plating lines: 1. Watts nickel, sulfamate nickel, and black nickel 2. Cyanide copper 3. Bright nickel, sulfamate nickel, and tin 4. Sulfamate nickel and electroless nickel 5. Silver and nickel 6. Silver and nickel 7. Lead 8. Gold and nickel EPA observed trench containment under the tanks to contain any spills. The larger nickel tanks, hydrochloric tanks, and sulfuric acid tanks exhaust to composite mesh pads (CMP). The cyanide tanks do not exhaust to CMPs. EPA also observed Advanced Plating take a qualitative surface tension measurement of a nickel tank with the wire. The bubble filled more than half of the loop in the wire. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Operation and Maintenance Plan CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: 1. 40 CFR Part 63, Subpart WWWWWW MACT Annual Certification/Report (40 C.F.R. 63.11509(c)) for years 2018 - 2021 2. Tank list and sizes 3. SDS for nickel and lead wetting agents 4. Records of wetting agent additions from January 2020 to today's date Page 3 of 5 DIGITAL SIGNATURES Digitally signed by Brittany Cobb Date: 2022.05.10 Brittany Cobb Report Author: ________________1_7:_02_:3_9 _-05_'0_0'__________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL MARSHALL 08:10:43 -05'00' Date: 2022.05.11 __________________________________ Page 4 of 5 Facility Name: Advanced Plating Technologies Facility Location: 405 W Cherry St, Milwaukee, WI 53212 Date of Inspection: March 16, 2022 APPENDICES AND ATTACHMENTS 1. Digital Image Log Page 5 of 5 Facility Name: Advanced Plating Technologies Facility Location: 405 W Cherry St, Milwaukee, WI 53212 Date of Inspection: March 16, 2022 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Laura Steel Image Number 1 2 3 4 5 6 7 8 9 10 11 File Name IMG_1415.JPG IMG_1416.JPG IMG_1417.JPG IMG_1418.JPG IMG_1419.JPG IMG_1420.JPG IMG_1421.JPG IMG_1422.JPG IMG_1423.JPG IMG_1424.JPG IMG_1425.JPG 2. Archival Record Location: https://usepa.sharepoint.com/:f:/r/sites/R5_Work/r5erc/ecad/AE CAB%20Library/Advanced%20Plating%20Technologies/Photos ?csf=1&web=1&e=TSmhjA Date and Time (3/16/2022, CT) 11:24 Description of Image Front of building 12:16 Tin/lead wetting Agent 12:17 Nickel wetting Agent 12:18 12:32 Sulfamate nickel wetting Agent Nickel tank/containment 12:33 Black nickel tanks 12:36 Bright nickel tanks 12:43 Sulfamate nickel tanks 12:43 Sulfamate nickel tanks 12:45 12:48 Sulfamate nickel containment Wire loop surface tension measurement Appendices Page 1 of 1