EPA v. HYDRO-PLATERS - APO/CAFO

Case summary

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 to properly inspect the scrubber systems and associated equipment; and (4) installed a high efficiency particulate air (HEPA) filter on System 1 to maintain the emission limit of 0.011 mg/dscm of total chromium for all open surface hard chromium electroplating tanks of System 1. The System 1 HEPA filter resulted in an emission reduction of approximately 38 pounds of chromium compounds emissions per year. This CAFO requires Hydro-Platers to pay a penalty of $12,215, complete a supplemental environmental project (SEP) of an estimated cost of $45,810, and resolves the Finding of Violation issued to Hydro-Platers on September 30, 2015. The SEP is designed to protect public health and the environment by reducing chromium compounds emissions from System 2, and consists of replacing the existing packed-bed system with a new three-stage composite mesh-pad mist eliminator of higher removal efficiency, and installing and operating a HEPA filter. The SEP will result in an emission reduction of approximately five pounds of chromium compounds emissions per year.

Defendants (1)

• HYDRO-PLATERSNamed in complaintNamed in settlement

Facilities (1)

• HYDRO-PLATERS, INC.

  3525 W. KIEHNAU AVE, MILWAUKEE, WI, 53295

  Registry ID: 110071499227

Statutes cited

• CAA 112 — Hazardous Air Pollutants

Enforcement conclusions (1)

• HYDRO-PLATERS - APO/CAFOentered 2018-12-21

  Primary law: CAA

  Federal penalty: $12,215 · SEP: $45,810

Timeline (5 milestones)

• 2018-12-14Complaint Filed/Proposed Order
• 2018-12-21Final Order Issued
• 2018-12-26Enforcement Action Data Entered
• 2019-11-18Enforcement Action Closed
• 2019-11-18Air Resolved