ENGINEERING EVALUATION REPORT

PLANT NAME Teikuro America Company, LTD

APPLICATION NUMBER 19981

PLANT NUMBER 1794

DATE 10 March 2009

1. BACKGROUND

Teikuro America of Hayward has filed this application to install a new HEPA Filtration Unit to their existing 

abatment system to comply with the emission requirements of the newly revised chrome plating ATCM. 

Accordingly, the chrome plating tank source will change as follows:

S-1 Hard Chrome Plating Bath - Abated by A-1 CMP & A-3 HEPA Filter Unit

Although there is fairly large buffer between the facility and other workers or residences, a new health risk 

screening assessment will be conducted at Teikuro. This risk evaluation will be based on the final permit 

level of hex chrome emissions 0.0015 mg/amp-hr at the permitted throughput of 3,000,000 a-hr/yr.

2. EMISSION CALCULATIONS

Current permitted emissions = (3,000,000 a-hr/yr)(0.03 mg/a-hr) = 0.198 lb/yr

Hex Chrome Emissions = (3,000,000 amp-hr/yr)(0.0015 mg/amp-hr)(lb/454E3mg) = 0.010 lb/yr

Net Emission Reduction, Hexavalent Chrome Emissions: 0.19 lb/yr

3. TOXIC EVALUATION

Based on the above emissions of chrome, the carcinogenic and chronic risks were estimated for the 

maximally exposed residential and industrial receptors. Stack emissions are exhausted vertically - 45 ft 

above ground level. Modeling runs were conducted for ground level receptors @ both urban and rural land 

use parameters. The highest result was used as the basis for the risk screen.

Modeling parameters are presented in Table 1 with the risk summary in Table 2 (based on worst case-rural 

dispersion). The modeling was performed using ISCST3 (BEEST) with source file inputs including the 

appropriate health potency factors, emission rates and unit conversions resulting in model outputs in units 

of risk in a million or hazard quotient. 

TABLE 1 RISK MODELING PARAMETERS

PARAMETER S-1 Chrome Plating Tanks

Met Data UNI96300.ASC

Exhaust Velocity 10,823 cfm

Stack Height 45’ @ 2.38’ Dia

Chrome Amp-Hours, annual 3 E 6

Chrome Emission Factor 0.0015 mg/a-hr

Chrome Emissions 0.198 lb/yr

TABLE 2 WORST CASE TOXIC RISK SUMMARY

RISK TYPE Cancer Risk

(X 1E-06)

Chronic,

Non-Cancer

Residential 0.26 8.6E-6

Worker 2.6 1.01E-04
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The residential cancer risk is less than 1 in a million. The cancer risk level for worker exposures are less 

than 10 in a million—which is an acceptable level with the application of TBACT controls. A controlled 

emission factor of 0.0015 (required by the chrome plating ATCM) has been determined to represent TBACT 

for this facility. The currently conditioned annual throughput of 3,000,000 a-hr/yr will remain and the 

maximum hex chrome emission factor will be changed from 0.03 mg/a-hr to 0.0015 mg/a-hr, effective 

October 23, 2009.

Chronic non-cancer risks are well within acceptable levels.

5. PERMIT REQUIREMENTS/DISCUSSION OF EXEMPTION

Not applicable.

6. DETERMINATION OF COMPLIANCE

A. Regulation 1 – General Provisions and Definitions

§1-301: Prohibits discharging emissions in quantities that cause injury, detriment, 

nuisance, or annoyance. Facility is installing abatement equipment to reduce emissions 

from currently permitted sources. Also, the operation complies with Reg 2-5, Toxic NSR, 

therefore Reg 1-301 has been addressed.

B. Permits – General Requirements, Regulation 2 Rule 1

Emissions decrease, therefore, notification requirements are not applicable.

C. Permits – New Source Review, Regulation 2 Rule 2 (dated 10/7/98)

1. BACT: The chrome control device that is being installed represents BACT for a 

facility of this size, fully expected to achieve a maximum emission level of 0.0015 

mg/amp-hr or less.

2. Offset Requirements: §2-2-303: Offsets are not applicable to this project.

3. Prevention of Significant Deterioration: §2-2-304: PSD requirements are not 

applicable.

D. Regulation 3 – Fees

Teikuro has complied with the fee requirements for this permit application.

E. Particulate Matter and Visible Emissions, Regulation 6

1. Section 301 prohibits for more than 3 minutes per hour, visible emissions as 

dark as or darker than Ringelmann 1 or equivalent opacity. Visible emissions 

have never been an issue at this facility. No change is expected.

2. Section 305 prohibits emissions of visible particles from causing a nuisance on 

property other than the operators. The aforementioned sources have never 

created a nuisance and with the expected reduced emissions are not expected 

to create a nuisance in the future.

3. Section 310 limits the particulate concentration in exhaust gases to 0.15 gr/dscf. 

The annual chrome emissions from this facility are an order of magnitude less 

than allowed in 1 dscf. No further discussion of this standard is needed.

F. NSPS/NESHAPS

The State Chrome Plating ATCM is far more stringent than the Federal NESHAP for 

chrome plating. Since this plating operation complies with the chrome ATCM, no further 

consideration of the NESHAP requirements is applicable.
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G. CEQA

This project is considered to be ministerial under the District’s CEQA Regulation 2-1-311. 

The engineering review for this project requires only the application of standard permit 

conditions and standard emissions factors and therefore is not discretionary as defined by

CEQA. 

7. CONDITIONS

Recommend the following conditions for the following sources:

S-1 Hard Chrome Plating Bath Abated by A-1 CMP and A-3 HEPA Filter

COND# 8012 --------------------------------------

 The owner/operator shall comply with the following

 Conditions for Source 1 Chrome Plating Tank.

 Basis refers to either BAAQMD Regulations/Rules

 or California Code of Regulations, Title 17, Section

 93102 - 93102.16 and associated appendices, unless

 otherwise noted. 

 1. Performance Standards 

 a) Emission Limits effective through 10-23-2009: 

 Emissions of hexavalent chromium shall not exceed

 0.03 mg per ampere-hour (mg/amp-hr) after abatement.

 [Basis: 93102.4(a)(1)] 

 b) Emission Limits effective 10-24-2009: 

 Emissions of hexavalent chromium shall not exceed

 0.0015 mg per ampere-hour (mg/amp-hr) after abatement.

 [Basis: 93102.4(b)(1) 

 c) Throughput: The total annual throughput shall not

 exceed 3 million ampere-hours in any consecutive

 12-month period. [Basis: 93102.4(b)(1)] 

 d) The requirements of Parts 1a and 1b of this condition

 and the O&M Plan provisions do not apply during periods

 of equipment breakdown, provided the provisions of the

 District's breakdown rules are met. [Basis: 93102.2(b)]

 2. Abatement 

 a) The owner/operator shall abate at all times during

 operation of S-1 with plating tank emissions vented

 through A-1 Duall Composite Mesh Pad (CMP) system and,

 upon HEPA Filter installation completion (before October 

 23, 2009), through A-3 HEPA Filter System.

 [Basis: 93102.4(b)] 
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 The ventilation and abatement system shall be properly

 maintained and kept in good working condition. 

 b) The owner/operator uses Hunter chemical HCA 6.2 fume

 suppressant bath additive to assist in housekeeping

 efforts around the plating tank. The plating bath

 surface tension shall not exceed 45 dynes/centimeter

 if measured with a stalagmometer, or 35

 dynes/centimeter if measured with a tensiometer.

 [Basis: 93102.9(d)(2)] 

 3. Source Test 

 a) The owner/operator shall perform a source test by

 October 24, 2009 to demonstrate compliance with the

 emission performance standard specified in part 1b. 

 An existing District-approved source test may be used

 to demonstrate compliance with this part, as long as

 the existing source test was conducted in

 accordance with ATCM Section 93102.7(b) & (c).

 [Basis: H&S Code 93102.7(a)(1)(A)] 

 b) The owner/operator shall perform source tests to

 demonstrate compliance according to the following

 schedule: 

 i. Unless Part 3.b)ii. is satisfied, subsequent

 source testing shall be performed no later

than 36 months after the date of the previous

District-approved source test demonstrating

compliance.

 ii. If the previous two consecutive source tests

 demonstrate compliance, the subsequent tests

shall be performed no later than 48 months

after the previous source test.

 iii. If a source test demonstrates non-compliance,

 then the owner/operator must perform another

 source test to demonstrate compliance.

Subsequent source tests to demonstrate

compliance shall be performed no later than

 24 months after the previous source test. If

 after two consecutive source tests at the 24

month frequency, both of which demonstrate

compliance, the source test frequency reverts

 to the original schedule in Part 3.b)i. 

 c) Non-compliant source test: After conducting a

 source test which demonstrates non-compliance the

 owner/operator shall review and adjust or repair the

 plating operation and associated emission control

 system. A source test to demonstrate compliance
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 shall be performed no later than 30 days after the

 chrome plating system adjustments/repairs are

 completed. 

 d) Any chrome plating bath that is non-operational at

 the time a source test is due does not have to be

 tested at that time. Upon subsequent start-up of

 any such bath, a source test shall be conducted

 within 30 days. 

 e) Source Testing Protocol: A written source test

 protocol based on 93102.7(c) shall be provided for

 District approval prior to conducting any source

 test for compliance. This source testing protocol

 shall include testing methods, length of sample

 period, plating facilities to be operated during the

 source test, sampling equipment and methods, as well

 as the planned date for the source test. 

 For the purpose of maintaining ongoing compliance,

 the following parameters shall be monitored and

 recorded at the listed frequency during the source

 testing period: 

 i. Bath surface tension: one time, before tank

 operation commences.

 ii. A-1 Pressure Drop: record pressure drop at

 least one time every 15 minutes of operation. 

 iii. A-3 Pressure Drop: record pressure drop at 

 least one time every 15 minutes of operation.

 f) The owner/operator shall contact the District Source

 Test Section at least 14 days in advance of the

 source test or as directed by the ATCM to obtain

 approval of the test protocol. The owner/operator

 shall notify the District Source Test Section at

 least 7 days in advance of each scheduled source

 test. [Basis: 93102.7] 

 g) If the owner/operator chooses to switch to a

 different bath additive, the plating tank must

 be re-source tested within 30 days to demonstrate

 compliance with the applicable Part 1 limit(s). 

 4. Training 

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

 calendar years thereafter, the owner or operator shall

 ensure that 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 for chrome
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 plating and anodizing. [Basis: 93102.5(b)] 

 5. 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 storage area. 

 b) Chromic acid materials shall be transported from

 storage to the bath in a closed container. 

 c) Any liquid or solid hexavalent chrome containing

 material that is spilled shall be contained or

 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. 

 6. 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/operator shall record the total ampere-hours

 used during each month.
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 [Basis: 93102.10(a), 93102.12(c)(1)] 

 b) A-1 Pressure Drop: The owner/operator shall

 continuously monitor the pressure drop across A-1

 Duall Composite Mesh Pad sytem . The pressure drop

 shall be maintained within plus or minus 2 inches of

 water of the value established during the most

 recent source test to demonstrate compliance with

 the emission limitations of Part 1. Pressure drop

 readings shall be recorded at a frequency of at

 least one time per operating week.

 [Basis: 93102.9(b), 9102.12(c)(2)] 

 c) Surface Tension Monitoring: In order to demonstrate

 compliance with Part 2.b), above, the surface

 tension shall be initially measured and recorded

 daily for 20 operating days. If there is no

 exceedance of the surface tension limit during the

 initial 20 operating day tests, the measurement

 frequency may be automatically extended to one time

 per calendar week of operation. If an exceedance

 occurs, the measurement frequency shall return to

 daily for 20 operating days, and weekly thereafter.

 [Basis: 93102.12(c)(4)(B)] 

 d) A-3 Pressure Drop: The owner/operator shall

 continuously monitor the pressure drop across A-3

 HEPA Filtration sytem . The pressure drop

 shall be maintained within minus 1⁄2 times to +2

 times the inches of water of the value established

 during the most recent source test to demonstrate 

 compliance with the emission limitations of Part 1.

 Pressure drop readings shall be recorded at a frequency of 

 at least one time per operating week.

 [Basis: 93102.9(b), 9102.12(c)(2)]

 7. 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

 air pollution control equipment and amp-hr

 meters/totalizers. [Basis: 93102.11] 

 b) A checklist to document the inspection, operation

 and maintenance for the chrome plating operation,
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 including steps to be taken to correct operating

 deficiencies. [Basis: 93102.11] 

 8. Inspection & Maintenance Frequency 

 a) The owner/operator shall perform visual inspections

 of the abatement systems and associated ductwork

 pursuant to ATCM Section 93102.10(a) at least once

 per calendar quarter. This visual inspection is to

 ensure that there is proper drainage, no unusual

 chromic acid buildup, and no evidence of chemical

 attack that would affect the structural integrity

 of the devices. [Basis: 93102.10(a) and Reg 2-5] 

 b) In order to demonstrate compliance with Part 8a,

 the owner/operator shall record the equipment being

 inspected, date, brief description of the working

 condition of the device during the inspections, any

 maintenance activities performed on the components

 of the air pollution control systems, and any

 actions taken to correct deficiencies found during

 the inspection. 

 9. Recordkeeping 

 The 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 the inspection, a brief description of the

 working condition and any corrective actions. 

 b) The owner/operator shall:

 [Basis: 93102.12] 

 i. Record the plating bath surface tension

 according to the testing frequencies noted

in Part 6.c), and

 ii. Record monthly and cumulative 12-month

 rectifier ampere-hour totals.

 iii. Record A-1 Duall CMP pressure drop

 at least once per operating week. 

 iv. Record A-3 HEPA pressure drop at least

 once per operating week. 

 c) Breakdown Records noting the occurrence,

 duration, cause (if known), and action taken. 
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 d) Records of excesses of the emission or ampere-hour

 limits of Part 1, the surface tension

 limits of Part 2, or the pressure drop limits

 established under Part 6.b). 

 e) Housekeeping Records demonstrating compliance

 with Part 5, above, including date and time of

 housekeeping activity. 

 10. Reporting 

 a) Source Test Reports: The owner/operator shall

 report source test results used to demonstrate

 compliance to the District Source Test Section no

 later than 60 days after the test date. The content

 of the source test reports shall contain the

 information identified in Appendix 1 of the

 applicable ATCM. Source test records shall be

 maintained onsite at the facility and made available

 to the District upon request, for a period of 5

 years from the date of the source test.

 [Basis: 93102.13(a)] 

 b) Annual Compliance Status Report: The owner/operator

 shall submit an annual compliance status report to

 the District on or before February 1, and shall

 include the following information for the preceding

 calendar year. 

 The content of the ongoing status shall include the

 information identified in Appendix 3 of the

 applicable ACTM. The report shall contain the name,

 title and signature of the responsible official who

 is certifying the accuracy of the report.

 [Basis: 93102.13(c)]

8. RECOMMENDATIONS

Issue permit to operate for hard chrome plating tank S-1 subject to Condition # 8012.

By:

Randy E. Frazier, P.E.

Senior Air Quality Engineer

10 March 2009