ENGINEERING EVALUATION REPORT

PLANT NAME S.J. Valley Plating

APPLICATION NUMBER 19117

PLANT NUMBER 5079

DATE 11

- 13

- 2008

1. BACKGROUND

On October 24, 2007, a major revision to the Airborne Toxic Control Measure (ATCM) for

Chromium Plating and Chrom ic Acid Anodizing became law in California. As a result, the permit

conditions for the District chrome platers (there are no chromic acid anodizers operating in the

BAAQMD) need to be revised to address these changes. Following is a listing of the source s

involved and the current and revised condition numbers. The ATCM can be found at the following

website: http://www.arb.ca.gov/toxics/atcm/chroatcm.pdf

Source Old Cond New Cond Bath Contro l Abatement

- 1 Abatement

- 2

1 3537 24179 Any Listed

Surfactant

In Section

93102.8(a) n/a n/a

District regulations allow the APCO to make changes of permit conditions, based on certain

criteria, enumerated in Reg 2

- 1

- 403:

**Permit Conditions:** Except as to p ermit applications reviewed in accordance with

Section 2

- 1

- 311, the APCO may impose any permit condition that he deems

reasonably necessary to insure compliance with federal or California law or District

regulations. For any permit application which was re viewed as a ministerial project in

accordance with Section 2

- 1

- 311, the APCO shall only impose permit conditions as

set forth in the District's Permit Handbook for the type of source being permitted. The

APCO may require the installation of devices for mea surement or analysis of source

emissions or ground

- level concentrations of air contaminants.

The proposed condition changes are to ensure compliance with the Chrome Plating ATCM,

revised 10

- 24

- 2007.

2. EMISSION CALCULATIONS

This facility is located mor e than 330 feet from the nearest sensitive receptor. The ATCM allows

facilities to operate at throughputs up to 50,000 amp

- hr/yr using only a surfactant, if the facility is

located more than 330 feet from the nearest sensitive receptor. This facility was previously

conditioned to a throughput of 4, 1 6 0,000 amp

- hr/hr, but has been plating less than 10,000 amp/yr.

Also, the facility intends to operate the plating tank with bath additives followed by an existing wet

scrubber downstream. No source test is pl anned, therefore the new conditioned limit will be

50,000 amp

- hr/yr.

Basis Throughput, a

- hr/yr Factor, mg/a

- hr Emissions, lb/yr

Current 4,160 ,000 0.01 0.0 92

Post

- ATCM 50,000 0.01 0.0011

Net Difference 4,110,000 0 0 .0 905AN 19117 / S.J. Valley Plating (P lant A5079 )

RE Frazier, P.E.

11/13/2008

2 3. CEQA

Since there is no in crease in the permitted emission levels, this application is exempt from CEQA

review per Reg 2

- 1

- 312.1.

4. BEST AVAILABLE CONTROL TECHNOLOGY

There is no increase in emission levels, therefore BACT is not applicable.

5. EXEMPTIONS

There are no applica ble exemptions.

6

. OFFSETS

Offsets are not applicable, since emissions do not increase , therefore no offset triggers are

exceeded.

7

. TOXIC EVALUATION

Emission levels decrease , therefore no toxic evaluation is required. Previous toxic risk

evaluatio ns have been conducted showing there are no significant risks to any member of the

public from these operations. A previous risk evaluation showed risks to the MEI were less than

10 in a million. Since the risk was not found to be significant when the em issions were 0.092 lb/yr,

we do not expect any increased risk at 0.0011 lb/yr.

8

. STATEMENT OF COMPLIANCE

The purpose of revising the permit conditions is to ensure that the facility complies with the newly

revised air toxic control measure.

9. CONDITI ONS

The previous version of Condition 3537 is presented in this application, as is the new Template

Condition 24179

. Condition 24179 is written in general terms for any facility located more than

330 feet from any sensitive receptor, with permitted throu ghput of less than or equal to 50,000

amp

- hr/yr.

10. RECOMMENDATIONS

Issue a Change of Condition letter for the aforementioned sources, subject to the new Template

Condition 24179

.

OLD CONDITION 3537

COND# 3537

---------------------- ----------------AN 19117 / S.J. Valley Plating (P lant A5079 )

RE Frazier, P.E.

11/13/2008

3 1. Throughput

The total annual combined throughput at source S

- 1 shall not

exceed 4,160,000 amp

- hrs in any consecutive twelve month

period.

2. Amp

- hours of operation

To comply with the above condition, S J Valley Plating shall

keep and maintain monthly records of current applied to this

source integrated over time, in units of ampere

- hours.

Ampere

- hour records to be monitored using non

- resettable amp

- hour meter. Ampere

- hour meter to be installed in a manner so

as to prevent the operation of the bath rectifier without

the simultaneous operatio n of the ampere

- hour meter.

3. Abatement

- Plating Bath Surface Tension

Source S

- 1 shall not be operated unless the plating bath is

operated with M&T Fumetrol 208 wetting

- agent additive or

equivalent with bath s urface tension not to exceed 45

dyne/cm.

4. Monitoring of Surface Tension

- Frequency

To demonstrate compliance with condition 3, above, surface

tension of source S

- 1 s hall be monitored at a frequency of

at least one time every 4,000 amp

- hours of rectifier

operation.

If after 40,000 amp

- hours of rectifier operation, the

surface tension monitoring resul ts indicate no exceedances

of the maximum surface tension standard identified in

Condition 3, above, the monitoring frequency can be reduced

to at least one time every 8,000 amp

- hours of rectifier

operation.

If further surface tension monitoring results indicate no

exceedances of the maximum surface tension standard

identified in Condition 3, above, after an additional 40,000

amp

- hours of operation, the monitoring freq uency can be

further reduced to at least one time every 40,000 amp

- hours

of rectifier operation.

5. Surface Tension Monitoring

- Testing Methods

Surface tension testing shall be conducte d as specified in

EPA Method 306

- B by the use of a stalagmometer or preciser

tensiometer as directed by manufacturers instructions.

Alternate test methods may also be used if the method has

been appropriately validated using EPA Method 301, Appendix

A, 40 CFR Part 63.AN 19117 / S.J. Valley Plating (P lant A5079 )

RE Frazier, P.E.

11/13/2008

4 6. Initial Performance Testing

- Required Records

In the process of conducting the initial performance

testing, the following records shall be kept:

a. Sampling and analysis procedures.

b. Raw data sheets.

c. Documentation of calculations.

d. Source testing results.

7. Recordkeeping

S J Valley Plating shall keep and maintain the following

records associated with source S

- 1:

a. Performance test records.

b. Operating throughput records (monthly, amp

- hour

thro ughput)

c. Records of chemical additions to chrome plating

bath.

8. Reporting

S J Valley Plating shall provide the BAAQMD with t he

following reports at the specified frequencies identified as

follows:

a. Notification of initial compliance status: Within 90

days of compliance performance test.

b. Annual total throughput of chrome plating operation

in ampere

- hours: Submit on an annual basis as

requested through the BAAQMD annual update program.

9. Retention of Records

S J Valley Plating shall retain copies of all of the above

required records and reports associated with the decorative

chrome plating operation for a period of at least five

years.

NEW CONDITION 24179

COND# 24179

-------------------- ------------------

The owner/operator shall comply with the following

Conditions for the hexavalent chrome plating source(s).

Basis refers to either BAAQMD Regulations/Rules or

California Code of Regulations, Title 17, Section 93102

- 93102.16 and associated appendices, unless otherwise noted.

Web address: http://www.arb.ca.gov/toxics/atcm/chroatcm.pdf

1. Performance Standards

Throughput: The total annual throughput shall no tAN 19117 / S.J. Valley Plating (P lant A5079 )

RE Frazier, P.E.

11/13/2008

5 exceed 50,000 ampere

- hours in any consecutive 12

- month

period. [Basis: 93102.4(b)(1)]

2. Abatement

Surface Tension: The owner or operator shall c ontrol

hexavalent chrome emissions by the use of one of the

following CARB

- approved chemical fume suppressants,

with the plating bath surface tension not to exceed the

following values in dynes/centimeter specific to the

chosen suppressant additive and surface tension test

method. [Basis: 93102.8(a)&(b)]

Suppressant Name Stalagmometer Tensiometer

(Manufacturer) (dynes/cm) (dynes/cm)

Benchbrite CR 1800 <40 <35

(Benchmark Products)

Clepo Chrome <40 <35

(MacDermid)

Fumetrol 140 <40 <35

(Atotech U.S.A.)

HCA

- 6.2 <32 <28

HCA

- 4 <32 <28

(Hunter Chemic al LLC)

3. Training

No later than October 24, 2009, and within every two

calendar years thereafter, the owner or operator shall

ensure tha t hexavalent chrome based plating operations

(including environmental compliance/recordkeeping) are

under the direction of the owner or operator or current

employee who is onsite and has completed the ARB

Compliance Assistance Training Course pertaining to

chrome plating and chrome anodizing.

[Basis: 93102.5(b)]

4. Housekeeping

The following housekeeping requirements shall be

implemented to reduce potential hexavalent chrome

fugitive emissions: [Basis: 93102.5(c)]

a) Chromic acid materials shall be stored in a closed

container in an enclosed stora ge area.

b) Chromic acid materials shall be transported from

storage to the bath in a closed container.

c) Any liquid or sold hexavalent chrome containing

material that is spilled shall be contained orAN 19117 / S.J. Valley Plating (P lant A5079 )

RE Frazier, P.E.

11/13/2008

6 cleaned up within one hour after being spilled.

d) Dragout shall be minimized by:

i. handling the plated parts so that chromic acid

is not dripped outside the tank, and

ii. installing splash guards at the tank to

minimize overspray and to ensure that chrome

solution is returned to the tank.

e) Surfaces within the chrome storage area and the

walkways and other areas potentially contaminated

with hexavalent chrome, shall be cleaned at least

one time every seven days by either HEPA vacuuming,

damp cloth hand wiping, wet mopping, use of non

- toxic dust suppressants or any other District

- approved method.

f) Buffing, grinding or polishing areas shall be

separated from the chrome plating operation by a

physical barrier, which may include, but is not

limited to vertical plastic strip curtains.

g) Chromium containing wastes generated as a result of

any of the above housekeeping activities shall be

stored, disposed of, recovered, or recycled using

practices that minimize fugitive dust.

5. Monitoring

a) Each rectifier shall be hard

- wired to a single non

- resettable meter which records ampere

- hours

continuously during rectifier operation. Each

ampere

- hour meter shall be installed and maintained

per manufacturer's specifications. The

owner/ope rator shall record the total ampere

- hours

used during each month.

[Basis: 93102.9(a), 93102.12(c)(1)]

b) Surface Tension monitoring: In order to

demonstrate compliance with part 2, above, t he

surface tension shall be initially measured and

recorded daily for 20 operating days. If there are

no exceedance of the surface tension standard during

the initial 20 operating day tests, the measurem ent

frequency may be automatically extended to one time

per calendar week of plating tank operation. If an

exceedance occurs, the measurement frequency shall

return to daily for 20 operating days, and we ekly

thereafter. [Basis: 93102.9(d), 93102.12(c)(4)]

Surface Tension Testing Methods: If using a

Tensiometer, test method shall be EPA Method 306B.

If using a Stalagmometer, test method is noted in

Section 93102 Appendix 8, or as per writtenAN 19117 / S.J. Valley Plating (P lant A5079 )

RE Frazier, P.E.

11/13/2008

7 manufacturer instructions, or in any other District

- approved procedure. [Basis: 93102.7(c)(3)]

6. Operation & Maintenance (O&M) Plan

The owner/operator shall prepare an operation and

maintenance plan for the chrome plating operation,

which shall be retained onsite and made available for

inspection upon request. Any revisions to the O & M

Plan shall be documented in an addendum and all

versions shall be maintained for a period of 5 years

after each revision to the plan. The O&M Plan shall at

a minimum include:

a) The inspection and maintenance requirements for the

chrome plating bath, amp

- hr meter(s)/totalizers,

stalagmometer or tensiometer. [Basis: 93102.11]

b) A checklist to document the inspection, operation

and maintenance for the chrome plating operation,

including steps to be taken to correct operating

deficiencies. [Basis: 93102.11]

7. Recordkeeping

Th e owner/operator shall maintain the following records

for at least five years, with the most recent two years

maintained onsite.

a) Inspection Records to demonstrate that such

inspections were done in accordance with the

provisions of Section 93102.10 and the O&M Plan.

Such records can take the form of a checklist and

shall identify the devices inspected, the date and

time of t he inspection, a brief description of the

working condition and any corrective actions.

b) The owner/operator shall:

[Basis: 93102.12]

i. Record the plating bat h surface tension

according to the testing frequencies noted

in Part 5.b), and

ii. Record monthly and cumulative 12

- month

rectifier ampere

- hour totals.

c) Breakdown Records noting the occurrence,

duration, cause (if known), and action taken.

d) Records of excesses of the ampere

- hour

limitations of Part 1 or the surface tension

limits of Part 2.

e) Housekeeping Records demonstrating compliance

with Part 4, above, including date and time ofAN 19117 / S.J. Valley Plating (P lant A5079 )

RE Frazier, P.E.

11/13/2008

8 housekeeping activity.

8) Reporting

The owner or operator shall submit an annual compliance

status report to the District [Compliance & Enforcement

Division] on or before February 1, and shall include the

following information for the preceding calendar year.

1. Company Information

a.Facility Name & Plant Number:

b.Facility Address:

c.Facility Phone Number:

d.Name of Owner or Operator

e.Distance from chrome sour ce to nearest receptor:

2. Relevant Requirements:

a.Maximum Ampere

- Hour Limit:

b.Surface Tension Limit to stay below:

c.Mist Suppressant Additive Used:

3. Actual cumulative ampere

- hour usage on a month by

month basis, for the calendar year reporting period.

4. Actual annual hexavalent chrome emissions (lb/yr):

Annual emissions = actual ampere

- hours multiplied by

0.02203, then divided by 1,000,000 = hex chrome

emissions in lb/yr

5. Summary of any excess emissions/exceeded monitoring

parameters

6. Were there any changes in monitoring, processes, or

controls since the last reporting period? Yes No

(circle the appropriate choice)

If yes, provide a description of the changes.

Certifications:

1) I (name and title) certify that the

inspection and maint enance requirements identified in the

Operation and Maintenance Plan were or were not followed

(circle the appropriate choice). If the requirements were

not followed, provide an explanation, with a copy of the

report required by Part 6 (a) of this Condition.

2) I (name and title) certify that the

following individuals have within the past 2 calendar years,

completed a CARB

- approved Environmental Compliance Training

Program.

Name: Name:

Title: Title:

Name:

Title:

Report Certified by:AN 19117 / S.J. Valley Plating (P lant A5079 )

RE Frazier, P.E.

11/13/2008

9 Title:

Date:

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