Document Y9MneJLQzmo4yYM26R7z1dK9D

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Milwaukee Plating Company, Milwaukee, WI Laura Steel, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Milwaukee Plating Company Facility Location: 1434 N. Vel R. Phillips Ave, Milwaukee, WI 53212 Date of Inspection: March 17, 2022 EPA Inspector(s): 1. Laura Steel, Environmental Engineer 2. Brittany Cobb, Environmental Engineer Other Attendees: 1. Alfred Mattacotti, President 2. Brooke Smith, Office Manager 3. Christopher Lee, Plant Manager 4. Joe Ilielo, Environmental Consultant Contact Email Address: nickel@milwaukeeplating.com Purpose of Inspection: To determine compliance with the Clean Air Act Facility Type: Nickel and hexavalent chrome electroplating and polishing facility Regulations Central to Inspection: 40 CFR Part 63 Subpart N: National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (NESHAP Subpart N), 40 CFR Part 63 Subpart WWWWWW: National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations, and any other applicable permits and regulations Arrival Time: 9:20 AM CST Departure Time: 10:45 AM CST Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Provided CBI warning to facility The following information was obtained verbally from Alfred Mattacotti, Brooke Smith, Christopher Lee, and Joe Ilielo, unless otherwise noted. Process Description: Milwaukee Plating Company (Milwaukee Plating Co. or facility) conducts decorative chrome electroplating, nickel electroplating, and polishing. The facility plates dicast, copper, and leaded steel and polishes aluminum and dicast parts, as well as chrome and nickel-plated parts, with 360 grit pads. The facility performs both "flash" (short-term) electroplating and normal electroplating for a longer duration. Chrome plating takes approximately 1 to 3 minutes, and nickel plating takes approximately 15 to 45 minutes. Their process is comprised of four lines: 1) Tin and silver, 2) Zinc, 3) Nickel and chrome (automatic line), and 4) Copper, nickel, and tin (hand line). There are two hexavalent chrome and three nickel electroplating tanks, with an approximate capacity of 4,000 amp-hours/year total. Approximately 10 gallons per month of Trichloroethylene solution is used as a degreaser. Wetting agents are used as the primary source of emission control for the chrome and nickel tanks, and a tensiometer is used to periodically check the surface tension in the chrome tanks. A custom-built packed bed scrubber is connected to the chrome tanks as an additional layer of emission control. The facility does not cover the nickel tanks when not in use. Staff Interview: Milwaukee Plating Co. operates from 6 AM to 11 PM, Monday through Friday and has 32 total employees. There have been no changes in ownership in the last 10 years. Surface tension is checked both by an analyst in an outside lab and in-house. There have been no changes in wetting agents in the past 4 years. An operator checks to ensure water is flowing within the scrubber as verification that it is working properly, but the facility does not record any Page 2 of 5 measurements. Visual inspections are completed 3 to 4 times per week, but no records are kept of these inspections. The scrubber filter is checked approximately once per month for metals, and these inspections have not been recorded for the past 2 years. The mist eliminator inside the scrubber is not inspected, and no performance tests have been completed on the scrubber. Annual compliance reports are completed biannually. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: The facility has containment systems around tanks that feed into on-site waste treatment. Nickel tanks were not covered or connected to the scrubber, and a strong odor near the nickel and chrome lines was noted. A distinct sweet smell was also noted in the plating area (not a typical acid/base smell). The trichloroethylene tank has its own containment, and it was stored in an unsealed, covered tank at an elevated temperature, as the solution was bubbling when observed. A pressure gauge on the side of the scrubber was read to be 0.8 inH2O during the inspection. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during the inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Wisconsin DNR air permit Ongoing compliance status reports for chrome tanks for the past 4 years in accordance with NESHAP Subpart N, Section 63.347(g)(3) Performance tests for scrubbers/wetting agents completed in the past 4 years Safety data sheets for wetting agents, chrome and nickel baths, trichloroethylene solvent, and sandpaper Current O&M plan(s) Wetting agent log sheets for auto and manual additions for the past 4 years Surface tension measurements for the past 4 years Original records of tensiometer calibrations with the name of the person who took each reading for the past 4 years Initial notification for chrome tanks in accordance with NESHAP Subpart N, Section 63.347(c) Initial notification for nickel tanks in accordance with NESHAP Subpart 6W, Section 63.11509 Annual certification of compliance reports for nickel tanks for the past 4 years in accordance with NESHAP Subpart 6W, Section 63.11509(c) Page 3 of 5  Records of inspection/routine maintenance of the overall emission capture system and scrubber for the past 4 years Details on control system(s) for nickel baths Concerns: It was noted to the company that trichloroethylene is a neurotoxin and that there are other options for degreasers. DIGITAL SIGNATURES Digitally signed by Steel, Steel, Laura Date: 2022.05.12 Laura Report Author: _______________15_:2_5:2_5_-0_5'_00_' ___________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL Date: 2022.05.12 _M__A_R__S_H_A__L_L___15_:1_0:_18_-0_5'_00_' _____________ Page 4 of 5 Facility Name: Milwaukee Plating Company Facility Location: 1434 N. Vel R. Phillips Ave, Milwaukee, WI 53212 Date of Inspection: March 17, 2022 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log Page 5 of 5 Contains Items Claimed as CBI - Non-Releasable Facility Name: Milwaukee Plating Company Facility Location: 1434 N. Vel R. Phillips Ave, Milwaukee, WI 53212 Date of Inspection: March 17, 2022 CONFIDENTIAL BUSINESS INFORMATION ATTACHMENT Facility Name: Milwaukee Plating Company Facility Location: 1434 N. Vel R. Phillips Ave, Milwaukee, WI 53212 Date of Inspection: March 17, 2022 All photos taken during the inspection. CBI Page 1 of 1 Contains Items Claimed as CBI - Non-Releasable Facility Name: Milwaukee Plating Company Facility Location: 1434 N. Vel R. Phillips Ave, Milwaukee, WI 53212 Date of Inspection: March 17, 2022 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Brittany Cobb 2. Archival Record Location: https://usepa- my.sharepoint.com/:f:/r/personal/cobb_brittany_epa_gov/Documents/ Electroplating%20Milwaukee/Milwaukee%20Plating%20Co/Milwau kee%20Plating%20Company%20Photos?csf=1&web=1&e=fssfjm Image Number 1 File Name IMG_1433.JPG Date and Time (incl. Time zone and DST) 3/17/22 9:16 AM CST Description of Image Facility exterior 2 IMG_1434.JPG 3/17/22 10:02 AM CST Electroplating tanks 3 IMG_1435.JPG 3/17/22 10:03 AM CST Nickel wetting agent label 4 IMG_1436.JPG 3/17/22 10:04 AM CST Chrome plating fume suppressant label 5 IMG_1437.JPG 3/17/22 10:05 AM CST Electroplating tanks 6 IMG_1438.JPG 3/17/22 10:07 AM CST Trichloroethylene tank 7 IMG_1439.JPG 3/17/22 10:08 AM CST Trichloroethylene tank label 8 IMG_1440.JPG 3/17/22 10:09 AM CST Trichloroethylene tank interior, 1 9 IMG_1441.JPG 3/17/22 10:09 AM CST Trichloroethylene tank interior, 2 10 IMG_1442.JPG 3/17/22 10:18 AM CST Scrubber monitoring window 11 IMG_1443.JPG 3/17/22 10:22 AM CST Scrubber pressure drop gauge 12 IMG_1444.JPG 3/17/22 10:25 AM CST Electroplating tanks Appendices Page 1 of 1