Document RaZvO9xpa5X68aJEZ9MQo6NrV

Region 2 Enforcement & Compliance Assurance Division Air Compliance Branch CAA Inspection Report Inspection Date: Facility Name: Facility Address: ICIS-Air ID #: EPA Lead Inspector: 4063 EPA Asst. Inspector: Facility Contact: 381-4967 State Inspector(s): Other Inspector(s): 2/14/2024 Quality Electroplating Corporation Parque Industrial Villa Blanca, Ave Sakura, Caguas, Puerto Rico 00725 PR0000007202500019 Katherine Marmanides, Enforcement Officer, marmanides.katherine@epa.gov, 212-637- Gloria Diaz-Galarza, Enforcement Officer, diaz-galarza.gloria@epa.gov, 787-977-5882 Alex Rivera, Enforcement Officer, rivera.alex@epa.gov, 787-977-5845 Jeannette Miranda, Environmental Manager, jeannettemirandapr@hotmail.com, 787- None. Elizabeth Hubbard, ERG Inspector, elizabeth.hubbard@erg.com, 919-468-7894 This report is a summary of observations and information gathered from the facility at the time of the inspection. The information provided does not constitute a final decision on compliance with Clean Air Act ("CAA") regulations or applicable permits, nor is it meant to be a comprehensive summary of all activities and processes conducted at the facility. Summary of Onsite Observations A. Opening Conference The representatives of the United States Environmental Protection Agency (EPA), Katherine Marmanides, Alex Rivera, and Gloria Diaz-Galarza, and Elizabeth Hubbard from Eastern Research Group, Inc. (ERG), arrived at the Quality Electroplating Corporation facility located at Parque Industrial Villa Blanca, Ave Sakura in Caguas, PR ("Quality," or "the facility") at approximately 9:30 am. The EPA and ERG representatives ("the inspectors") were met upon arrival by Jeannette Miranda, Environmental Manager for Quality. At approximately 9:40 am, the inspectors and Ms. Miranda met in a conference room for the opening conference. The inspectors presented their identification credentials and provided an overview and scope of the inspection. The inspectors took a photo of a sign in the conference room that lists the services Quality provides to its customers (see image 1). The list of digital images taken during the inspection is included in Appendix A. Quality Electroplating Corporation - PR0000007202500019 1 2/14/2024 The inspectors asked Ms. Miranda to describe the facility's operations and history. Ms. Miranda informed the inspectors that the company started in 1976 and has been operating at its current location since approximately 1981 when it relocated from a smaller facility nearby. The facility has approximately 90 employees and operates in two shifts that run from 6 am to 2:30 pm and from 2 pm to 10:30 pm, Monday through Friday. The facility electroplates various types of metal parts and performs powder spray coating, though Ms. Miranda said electroplating accounts for most of its operations. The facility also has its own wastewater treatment plant. Types of metal parts that are electroplated and coated at the facility include iron, copper, brass, aluminum, zinc, and copper. The inspectors asked Ms. Miranda to describe the electroplating process. Ms. Miranda said that customers send metal parts to the facility and provide specifications for what they need done to the parts. Typically, parts are electroplated or coated to prevent corrosion. When Quality receives the parts, they first degrease them, then the parts are rinsed with water to remove the degreaser. The parts then go through an acid bath, are rinsed again, and are then electroplated. After electroplating, the parts are dried in tumblers with hot air, then an absorber is used to help the parts dry further. Once the parts are dry, they are inspected and go through a certification process to ensure they meet client specifications. After Quality processes the parts, they are packaged and then the customer is responsible for having the parts returned to them or distributed to customers. Ms. Miranda said that some of Quality's larger customers include Eaton and ABB. The inspectors asked whether chromium electroplating is performed at the facility. Ms. Miranda responded that the facility has not performed chromium electroplating within the past year. She was unsure of whether the facility had records of the last time the chrome process was run. She explained that the facility still has the chromium electroplating tank, but they provide services to many customers in Europe that no longer want hexavalent chromium products anymore. Ms. Miranda said that the facility still has the hexavalent chromium tank because it is still occasionally used for smaller requests, but they no longer use hexavalent chromium for any of Quality's larger clients. The inspectors asked Ms. Miranda what types of air pollution control devices are used at the facility. Ms. Miranda responded that some of their production lines have extractors that run at high temperatures. She said that the facility also has a scrubber that is no longer used because it was only for the hexavalent chromium process. She informed the inspectors that the facility is working on a plan to separate different areas of the facility because some of the processes generate emissions with the potential to react with each other. Ms. Miranda explained that an engineering assessment is being done to determine how they can better handle these processes and improve indoor air quality. She told the inspectors that it is getting difficult to maintain a healthy environment for the facility employees because of the hot weather since the main way the process area is ventilated is by pulling in outside air. Ms. Miranda told the inspectors that the facility has started bringing in a doctor each Friday to do health assessments of the employees. She said that this practice is voluntary, and the goal is to reduce downtime from employees missing work from getting sick or going to doctor's appointments. The inspectors asked whether the gas scrubber for the chromium line is equipped with a flow meter and pressure and temperature transmitters. Ms. Miranda said yes that the scrubber has a flow meter and pressure and temperature transmitters. She told the inspectors that the facility performs calibrations and inspections of these monitoring devices. She also informed the inspectors that the facility performs surface tension measurements on the chromium tank. The inspectors noted that 40 CFR Part 63 Subpart N--National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks has different emission limits for chromium depending on when the chromium electroplating tank was built. They asked Ms. Miranda Quality Electroplating Corporation - PR0000007202500019 2 2/14/2024 when the chromium tank was built and how the facility calculates chromium emissions. She did not know when it was built but said that it should be listed in the facility's permit. The inspectors noted that the facility is required under 40 CFR Part 63 Subpart N to submit semi-annual compliance reports to the Puerto Rico Department of Natural and Environmental Resources (DNER) and asked if they could review the most recent report. Ms. Miranda indicated that she was unaware of this requirement and told the inspectors that the facility does not submit reports to DNER in a semi-annual basis. The inspectors noted that the facility's 2018 operating permit limits emissions from its boilers to 0.3 pounds per million British thermal units of heat supplied. It also limits 6-minute average opacity from the boilers to 20%. The inspectors asked how the facility determines boiler emissions and how frequently the facility performs opacity readings. They also asked for additional information about the boilers such as the type of fuel they use and their maintenance schedule. Ms. Miranda told the inspectors that the boilers use diesel fuel, and that the facility submits monthly fuel use reports to DNER. She went to retrieve the facility's maintenance supervisor to answer the remaining questions about the boilers. Ms. Miranda consulted with the facility maintenance supervisor, and told the inspectors that the facility hires a contractor to perform preventative maintenance, opacity tests, and emission tests on the boilers every two months. The facility also perform more intensive maintenance on the boilers annually. He informed the inspectors that the contractor provides a report following each service. The inspectors asked whether the facility operates a continuous monitoring system (CMS) for the boilers. The maintenance supervisor said yes. The inspectors asked whether facility follows a sitespecific monitoring plan for operating the CMS. The maintenance supervisor responded that the facility does not have a site-specific monitoring plan, but they do follow a checklist for operating the boilers and CMS. The inspectors asked whether the facility submits annual certification of compliance reports for the boilers as required by 40 CFR Part 63 Subpart JJJJJJ--National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources. Ms. Miranda responded yes. The inspectors asked Ms. Miranda how many emergency generators the facility has on site. Ms. Miranda told the inspectors the facility has two main generators and a third on standby. The inspectors asked whether the generators have hour meters. Ms. Miranda said that two of the three generators have hour meters. The inspectors asked whether the facility has any emission controls for its powder spray coating operations and whether the operations are enclosed. Ms. Miranda told the inspectors that the facility uses filters to control emissions from powder coating and that the powder coating operations are performed in an area of the facility that is separate from other operations. The inspectors asked what type of applicator is used for powder coating. Ms. Miranda informed the inspectors that electrostatic spray guns are used. The following documents were requested during the opening conference and on a later day, via email, for review: Records indicating when the chromium electroplating tanks were installed (records for both trivalent and hexavalent chromium tanks) Monthly fuel reports submitted to DNER over the past 12 months Manufacturing specifications for the emergency generators Manufacturing specifications for the sludge dryer Operation and maintenance schedule for all emission control equipment Operation and maintenance schedule for engines (emergency generators and sludge dryer) Operation and maintenance schedule for chromium tank Safety data sheets (SDSs) for all cleaning agents/solutions used at the facility SDSs for the coatings used in the powder spray coating operations Quality Electroplating Corporation - PR0000007202500019 3 2/14/2024  For the past three 3 years, records of the following: o Annual reports (and semi-annual reports, if available) submitted to DNER o Calibrations for the gas scrubber o Gas scrubber inspections o Chromium emission calculations (both trivalent and hexavalent chromium calculations, if available) o Chromium tank surface tension measurements o Chromium tank maintenance records o Records of when and how much suppressing/wetting agent was added to the chromium tank o Boiler maintenance records o Boiler emission calculations o Boiler annual reports o Boiler checklists o Emergency generator fuel use and operating hours o Sludge dryer fuel use and operating hours o Logs of amounts of chromic acid, nitric acid, and sulfuric acid consumed o Logs of amounts of cleaning agents/solutions consumed o Gas scrubber maintenance records o Records of malfunctions for air pollution control equipment B. Facility Tour At approximately 11:15 am, Ms. Miranda led the inspectors on a tour of the facility. The inspectors explained that during the facility tour, they would capture digital images of the facility's processes and emission points using a digital point and shoot camera that is not intrinsically safe. They explained that the facility would have the opportunity to claim any of the photos as confidential business information (CBI), if needed. Ms. Miranda did not express any concerns with the inspector's capturing photos. The group started at the electroplating area, then visited the large part powder spray coating area, the small part powder spray coating area, and the boilers and emergency generators located outside of the building. The inspectors also observed a coating incinerator and a sand blasting operation of which they were previously unaware. See images 2-45. At the electroplating area, the inspectors noted a strong odor near the process water holding tanks. They also noted that the floor was wet and slick in many areas, there were open barrels of unlabeled liquid, and the process equipment appeared dirty and had evidence of corrosion and leaks. Ms. Miranda showed the inspectors parts that had recently been electroplated with trivalent chromium, and the inspector's observed tanks that appeared to be in use that were labeled "cromato" (chromate) (see images 2 and 5). The inspectors pointed out that Ms. Miranda had said during the opening meeting that the facility does not currently perform chromium electroplating, but it appeared there was chromium electroplating taking place. There also appeared to be multiple chromium tanks rather than just one, and the tanks did not appear to have any emission controls. Ms. Miranda clarified that she had meant the facility does not currently perform hexavalent chromium electroplating, but the facility does perform trivalent chromium electroplating. She noted that the facility only has one hexavalent chromium electroplating tank which has a scrubber. The inspectors informed Ms. Miranda that trivalent chromium is still considered a hazardous air pollutant under the Clean Air Act, and therefore it is possible that the trivalent chromium electroplating processes may be subject to some National Emission Standards for Hazardous Air Pollutants (NESHAP) requirements. The inspectors observed a pipe in the Quality Electroplating Corporation - PR0000007202500019 4 2/14/2024 electroplating area that had visible vapor emissions leaking from a coupling (see image 8). Ms. Miranda told the inspectors the emissions were water vapor. Ms. Miranda led the inspectors to the hexavalent chromium electroplating tank, which was not in use during the inspection. The inspectors noted that there were no visible monitoring devices such as a flow meter, pressure transmitter, or temperature transmitter. There was one gauge located above the hexavalent chromium electroplating tank in front of the scrubber inlet, but the face of the gauge was too dirty to read. The scrubber itself was not visible from inside the building, but the scrubber inlet and exhaust piping were visibly dirty and corroded (see images 10-12). The inspectors asked whether there are any monitoring devices for the scrubber. Ms. Miranda told the inspectors that there are monitoring devices located on the roof of the building, which is where the scrubber is located. She said that the operators test whether the scrubber is running by placing a sheet of paper in front of the scrubber inlet to ensure there is air flow. Ms. Miranda also told the inspectors that surface tension measurements are taken regularly when the tank is in operation, and a suppressing agent, Fumetrol 140, is added manually to reduce the surface tension when it is nearing 45 dynes per centimeter. At the large part powder coating area, the inspectors noted there are plastic strip curtains hanging to separate the coating area from other areas of the building, but the curtains do not extend all the way to the ceiling (see image 13). The inspectors also observed air filters on the back wall of the coating area which appeared very dirty (see image 14). Ms. Miranda indicated these filters are the only form of emission control in this area. She showed the inspectors two coating drying ovens for large parts which have open ended exhaust pipes that vent back into the room (see images 15, 18, and 19). At the small part powder coating area, the inspectors noted there is no barrier separating the area where powder coating takes place from the rest of the building. The inspectors observed an operator spray coating parts without a respirator (see image 20). When the inspectors pointed this out to Ms. Miranda, Ms. Miranda and another facility employee asked him to put a respirator on, which he did. Ms. Miranda showed the inspectors that there is an air intake device located behind where the operator was standing, several feet from where the spray coating was taking place (see image 28), which she said is routed to a filter. She pointed out the filter to the inspectors later when the group walked outside (see images 27 and 29). Ms. Miranda also showed the inspectors a polisher which she said is used to polish small parts prior to powder coating (see image 21). The inspectors observed that the small part drying oven has an exhaust pipe that vents to the outside of the building with no apparent control device (see images 30 and 31). Outside the building, the inspectors noticed an enclosure with several metal chairs sitting inside of it that appeared to have been stripped of their original coating (see image 22). Ms. Miranda informed the inspectors that the enclosure is an incinerator which the facility uses to remove coatings from metal items. The incinerator did not appear to have any emission controls and is vented through the roof of the building where it is located (see image 25). The inspectors observed a large machine running which appeared to be a control device. Ms. Miranda informed the inspectors that the device is the filter for the facility's sand blasting operation and that it contains 8 filters (see image 24). She told the inspectors she was not sure why it was running because there was no sand blasting being done at that time. The inspectors observed the inside of the sand blasting building and noted that the air intake on the ceiling of the building appeared to have a pre-filter that was in poor condition (see image 26). Throughout the facility, the inspectors noted that the main form of ventilation was open windows and doors and large fans used to pull in outside air. C. Closing Conference Quality Electroplating Corporation - PR0000007202500019 5 2/14/2024 At approximately 1:15 pm, the group returned to the conference room for a closing conference. The inspectors thanked Ms. Miranda for her time and cooperation during the inspection. The inspectors went back through the documents that were requested during the opening conference and informed Ms. Miranda that they would be following up via email with the list of documents as well. At approximately 1:30 pm, the inspectors departed from the facility. Appendices A. Digital Image Log End of Report Lead Inspector's Name: Katherine Marmanides Katherine G. Digitally signed by Katherine G. Marmanides X Marmanides Date: 2024.04.15 15:13:48 -04'00' Lead Inspector Assisting Inspector's Name: Gloria Diaz-Galarza GLORIA DIAZ- Digitally signed by GLORIA DIAZ-GALARZA X GALARZA Date: 2024.04.16 12:21:06 -04'00' Assisting Inspector Supervisor's Name: Harish Patel HARISH X PATEL Digitally signed by HARISH PATEL Date: 2024.04.16 14:36:40 -04'00' Supervisor Quality Electroplating Corporation - PR0000007202500019 6 2/14/2024 Appendix A: Digital Image Log for Quality Electroplang Corporaon, Caguas, PR Facility Address: Inspectors: Parque Industrial Villa Blanca, Ave Sakura, Katherine Marmanides, EPA, Caguas, PR 00725 Gloria Diaz-Galarza, EPA, Alex Rivera, EPA, Elizabeth Hubbard, ERG File name: Appendix A Digital Image Log Quality Electroplang_2024-03-22 Image Number 1 File Name DSC01249.JPG Descripon Image numbers: DSC01249.JPG - DSC01267.JPG, DSC01269.JPG DSC01284.JPG, DSC01286.JPG - DSC01288.JPG, DSC01290.JPG, DSC01291.JPG, DSC01293.JPG DSC01296.JPG, DSC01298.JPG, MOV01268.AVI Date Taken Time taken 2/14/2024 9:32 am Sign in conference room detailing services offered by Quality Electroplang Corp. Appendix A Quality Electroplang Corporaon Inspecon Report 1 2 DSC01250.JPG 2/14/2024 11:18 am Metal parts electroplated with yellow and clear chrome (trivalent chromium). Appendix A Quality Electroplang Corporaon Inspecon Report 2 3 DSC01251.JPG 2/14/2024 11:18 am Part dryers for electroplang process. Appendix A Quality Electroplang Corporaon Inspecon Report 3 4 DSC01252.JPG 2/14/2024 11:25 am Part cleaning baths for electroplang process. Appendix A Quality Electroplang Corporaon Inspecon Report 4 5 DSC01253.JPG 2/14/2024 11:28 am Phosphate, cleaning, and trivalent chromate baths for electroplang process. Appendix A Quality Electroplang Corporaon Inspecon Report 5 6 DSC01254.JPG 2/14/2024 11:28 am Open, unlabeled barrels of liquid located in electroplang process area. Appendix A Quality Electroplang Corporaon Inspecon Report 6 7 DSC01255.JPG 2/14/2024 11:29 am Zinc electroplang line. Appendix A Quality Electroplang Corporaon Inspecon Report 7 8 DSC01256.JPG 2/14/2024 11:34 am Leaking pipe with visible vapor emissions. Appendix A Quality Electroplang Corporaon Inspecon Report 8 9 DSC01257.JPG 2/14/2024 11:36 am Open tank in electroplang area with greenish liquid flowing in. Facility employee told inspectors this is a soapy water bath for cleaning parts. Appendix A Quality Electroplang Corporaon Inspecon Report 9 10 DSC01258.JPG 2/14/2024 11:55 am Hexavalent chromium electroplang tank. Appendix A Quality Electroplang Corporaon Inspecon Report 10 11 DSC01259.JPG 2/14/2024 11:55 am Hexavalent chromium electroplang tank and gas scrubber air intake. Appendix A Quality Electroplang Corporaon Inspecon Report 11 12 DSC01260.JPG 2/14/2024 11:55 am Exhaust pipe routed to hexavalent chromium electroplang tank gas scrubber. Appendix A Quality Electroplang Corporaon Inspecon Report 12 13 DSC01261.JPG 2/14/2024 12:06 pm Large part powder spray coang area. Strip curtain open and does not extend all the way to the ceiling. Appendix A Quality Electroplang Corporaon Inspecon Report 13 14 DSC01262.JPG 2/14/2024 12:06 pm Air filters on back wall of large part powder spray coang area. Appendix A Quality Electroplang Corporaon Inspecon Report 14 15 DSC01263.JPG 2/14/2024 12:08 pm Inside of spray coat drying oven for large parts. Appendix A Quality Electroplang Corporaon Inspecon Report 15 16 DSC01264.JPG 2/14/2024 12:10 pm Etching baths used to process large parts prior to powder spray coang. Appendix A Quality Electroplang Corporaon Inspecon Report 16 17 DSC01265.JPG 2/14/2024 12:10 pm Etching baths used to process large parts prior to powder spray coang. Appendix A Quality Electroplang Corporaon Inspecon Report 17 18 DSC01266.JPG 2/14/2024 12:17 pm Second spray coat drying oven for large parts. Appendix A Quality Electroplang Corporaon Inspecon Report 18 19 DSC01267.JPG 2/14/2024 12:18 pm Open-ended exhaust pipe for second spray coat drying oven for large parts. Appendix A Quality Electroplang Corporaon Inspecon Report 19 20 DSC01269.JPG 2/14/2024 12:23 pm Facility employee powder spray coang small parts (not wearing respirator). Appendix A Quality Electroplang Corporaon Inspecon Report 20 21 DSC01270.JPG 2/14/2024 12:24 pm Polisher used to prepare small parts for powder spray coang. Appendix A Quality Electroplang Corporaon Inspecon Report 21 22 DSC01271.JPG 2/14/2024 12:31 pm Incinerator with metal chairs inside. Used for removing coangs from parts. Appendix A Quality Electroplang Corporaon Inspecon Report 22 23 DSC01272.JPG 2/14/2024 12:34 pm Pipes going through wall of sand blasng building (pipes not in use). Appendix A Quality Electroplang Corporaon Inspecon Report 23 24 DSC01273.JPG 2/14/2024 12:34 pm Filter for sand blasng process. Appendix A Quality Electroplang Corporaon Inspecon Report 24 25 DSC01274.JPG 2/14/2024 12:37 pm Open incinerator stack on roof of building. Appendix A Quality Electroplang Corporaon Inspecon Report 25 26 DSC01275.JPG 2/14/2024 12:42 pm Filter air intake on ceiling of sand blasng building. Pre-filter in poor condion. Appendix A Quality Electroplang Corporaon Inspecon Report 26 27 DSC01276.JPG 2/14/2024 12:45 pm Filter for small part powder spray coang process. Appendix A Quality Electroplang Corporaon Inspecon Report 27 28 DSC01277.JPG 2/14/2024 12:47 pm Air intake for small part powder spray coang filter. Appendix A Quality Electroplang Corporaon Inspecon Report 28 29 DSC01278.JPG 2/14/2024 12:47 pm Air intake for small part powder spray coang filter. Appendix A Quality Electroplang Corporaon Inspecon Report 29 30 DSC01279.JPG 2/14/2024 12:48 pm Open-ended exhaust pipe for small part coang drying oven. Appendix A Quality Electroplang Corporaon Inspecon Report 30 31 DSC01280.JPG 2/14/2024 12:49 pm Open-ended exhaust pipe for small part coang drying oven. Appendix A Quality Electroplang Corporaon Inspecon Report 31 32 DSC01281.JPG 2/14/2024 12:51 pm Four exhaust stacks. Boiler #1 stack is dark, narrow stack second from the le. Appendix A Quality Electroplang Corporaon Inspecon Report 32 33 DSC01282.JPG 2/14/2024 12:54 pm Boiler #2 inspecon cerficaon. Appendix A Quality Electroplang Corporaon Inspecon Report 33 34 DSC01283.JPG 2/14/2024 12:55 pm Boiler #2. Appendix A Quality Electroplang Corporaon Inspecon Report 34 35 DSC01284.JPG 2/14/2024 12:56 pm Boiler #1 inspecon cerficaon. Appendix A Quality Electroplang Corporaon Inspecon Report 35 36 DSC01286.JPG 2/14/2024 12:57 pm Boiler #1. Appendix A Quality Electroplang Corporaon Inspecon Report 36 37 DSC01287.JPG 2/14/2024 12:58 pm Three exhaust stacks. Boiler #2 stack is on the le. Appendix A Quality Electroplang Corporaon Inspecon Report 37 38 DSC01288.JPG 2/14/2024 1:00 pm Electroplang rack cleaning room with exhaust fan on wall above cleaning baths. Appendix A Quality Electroplang Corporaon Inspecon Report 38 39 DSC01290.JPG 2/14/2024 1:03 pm Plate on backup electricity generator. Appendix A Quality Electroplang Corporaon Inspecon Report 39 40 DSC01291.JPG 2/14/2024 1:03 pm Backup electricity generator exhaust under blackened roof. Appendix A Quality Electroplang Corporaon Inspecon Report 40 41 DSC01293.JPG 2/14/2024 1:04 pm Backup electricity generator operang hour meter. Appendix A Quality Electroplang Corporaon Inspecon Report 41 42 DSC01294.JPG 2/14/2024 1:05 pm Backup electricity generator exhaust under blackened roof. Appendix A Quality Electroplang Corporaon Inspecon Report 42 43 DSC01295.JPG 2/14/2024 1:06 pm Plate on emergency generator. Appendix A Quality Electroplang Corporaon Inspecon Report 43 44 DSC01296.JPG 2/14/2024 1:07 pm Plate on emergency generator. Appendix A Quality Electroplang Corporaon Inspecon Report 44 45 DSC01298.JPG 2/14/2024 1:08 pm Plate on emergency generator. Appendix A Quality Electroplang Corporaon Inspecon Report 45