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 thei r 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

Ne t Emission Reduction, Hexavalent C hrome 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. S tack emissi ons are exhausted vertically

- 4 5 ft

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

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

.

Modeling parameters are presented in T able 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 mode l 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 4 5’ @ 2.38’ Dia

Chrome Amp

- Hours, annual 3 E 6

Chrome E mission 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

- 04Teikuro America Company, LTD

BAAQMD Plant 1794

AN 19981; 10 March 2009

REFrazier

2 The residential can cer risk is less than 1 in a mil lion. 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 con trolled

emission factor of 0.0015 (required by the chrome plating ATCM) has been determined to repres ent 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 caus e 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

– Gene ral 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 repres ents BACT for a

facility of this size, fully expected to achieve a maximum emi ssion 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, visib le 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

ch rome plating. Since t his plating operation complies with the chrome ATCM , no further

consideration of the NESHAP requirements is applicable

.Teikuro America Company, LTD

BAAQMD Plant 1794

AN 19981; 10 March 2009

REFrazier

3 G. CEQA

This project is considered to be ministerial under the District’s CEQA Regulation 2

- 1

- 311.

The engine ering 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 ei ther 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 t his 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 comple tion (before October

23, 2009), through A

- 3 HEPA Filter System.

[Basis: 93102.4(b)]Teikuro America Company, LTD

BAAQMD Plant 1794

AN 19981; 10 March 2009

REFrazier

4 The ventilation and abatement system shall be properly

maintained and kept in good working cond ition.

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/ce ntimeter

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

pla ting operation and associated emission control

system. A source test to demonstrate complianceTeikuro America Company, LTD

BAAQMD Plant 1794

AN 19981; 10 March 2009

REFrazier

5 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 bat h, 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 approva l 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, sampli ng 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 li sted frequency during the source

testing period:

i. Bath surface tension: one time, before tank

operation commences.

ii. A

- 1 Pressure Drop: record pressure dro p 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 chromeTeikuro America Company, LTD

BAAQMD Plant 1794

AN 19981; 10 March 2009

REFrazier

6 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

co ntainer 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

ma terial 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 wi thin 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 chrom e 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 housekeep ing 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.Teikuro America Company, LTD

BAAQMD Plant 1794

AN 19981; 10 March 2009

REFrazier

7 [Basis: 93102.10(a), 93102.12(c)(1)]

b) A

- 1 Pressure Drop: The owner/operator shall

continuousl y 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 the re 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 exceed ance

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

con tinuously 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 a vailable 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 sh all 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,Teikuro America Company, LTD

BAAQMD Plant 1794

AN 19981; 10 March 2009

REFrazier

8 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 leas t 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 integ rity

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 wor king

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 duri ng

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 Par t 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.Teikuro America Company, LTD

BAAQMD Plant 1794

AN 19981; 10 March 2009

REFrazier

9 d) Records of excesses of the e mission 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 complianc e

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 o r before February 1, and shall

include the following information for the preceding

calendar year.

The content of the ongoing status shall include the

information iden tified 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. RECOMMEND ATIONS

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