ENGINEERING EVALUATION REPORT

PLANT NAME Roll Technology West

APPLICATION NUMBER 19111

PLANT NUMBER 7546

DATE 11

- 13

- 2008

1. BACKGROUND

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

Chromium Plating and Ch romic 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 sou rces

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 Con trol Abatement

- 1 Abatement

- 2

1 8641 8641 Fumetrol 140 A

- 1 Mapco

Enforcer III 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 permit appl ications 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 reviewed 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 measurement o r 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

The new permitted emission level will be 0.0015 mg/a

- hr. Hence the following shows the

permitted hex chrome emission rates before and after the permit condition modification.

Basis Throughput, a

- hr/yr Factor, mg/a

- hr Emissions, lb/yr

Current 35,000,000 0.006 0.4626

Post

- ATCM 35,000,000 0.0 015 0.1156

Net Difference 0 0.0045 0. 347

3. CEQA**AN 19110/U.S. Mint (Plant A5474)**

**R E Frazier, P.E.** 

**11/13/2008**

2 Since the change of conditions will result in a decrease in the permitted emission levels, this

application is exempt from CEQA review per Reg 2

- 1

- 312.1.

4. BEST AVAILABLE CONTROL TECHNOLOGY

Emission s are decreasing, therefore BACT is not applicable.

5. EXEMPTIONS

There are no applicable exemptions.

6

. OFFSETS

Offsets are not applicable, since emissions decrease, therefore no offset triggers are exceeded.

7

. TOXIC EVALUATION

Permitted emissio n levels decrease, therefore no toxic evaluation is required. Previous toxic risk

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

public from these operations. It should be noted that the risks were less than 1 0 in a million at the

previous emission level, 0.4626 lb/yr. We would therefore expect the risk at the new control level

to remain below 10 in a million.

8

. STATEMENT OF COMPLIANCE

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

revised air toxic control measure.

9. CONDITIONS

The previous version of Condition 8641 is presented in this application, as is the revised Condition

8641

.

10. RECOMMENDATIONS

Issue a Change of Condition letter for the a forementioned sources, subject to the revised

Condition 8641

.

OLD CONDITION 8641

COND# 8641

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

1. Annual Usage

The total annual (net) throu ghput

from chrome plating tank S1 shall

not exceed 35 million ampere

- hours

in any consecutive twelve

- month**AN 19110/U.S. Mint (Plant A5474)**

**R E Frazier, P.E.** 

**11/13/2008**

3 period.

2. Abatement

This source shall not be operated

unless all chrome plating tank

emissions are vented through A1

MAPCO Enforcer III Chrome Scrubber.

All emissions shall be exhausted at

a hei ght of at least 43 feet

(13 meters) above grade. The abatement

system shall be well maintained and

kept in good operating condition.

3. Emission Limits

Emissions of hexavalent chromium

shall not exceed 0.006 milligram per

ampere

- hour (mg/a

- hr) after abatement.

4. Source Test

Biennial Source Test: To assist in

demonstrating ongoing compliance with

permit condition 3 above, Roll

Technology West shall perform a source

test (according to a District approved

protocol) at a frequency of not less

than once every 24 months after the

previous source test.

Source Testing Protocol: A written

source test protocol shall be

submitted for District approval prior

to conducting any source test for

compliance. This source test protocol

shall include testing methods, length

of sample period, plating facilities

to be operating during the source test,

sampling equi pment and methods,

parameters to be monitored, as well

as the planned date for the source test.

For the purpose of establishing an ongoing

compliance parameter, the scrubber

pressure drop shall be moni tored and

recorded at a frequency of at least

once every 15 minutes during the source

testing period.

All source tests used to demonstrate

compliance shall determ ine the mass

emissions of both total and hexavalent

chromium in g/hr, mg/a

- hr, and mg/dscm

as emitted after abatement. Source

tests shall be conducted while both**AN 19110/U.S. Mint (Plant A5474)**

**R E Frazier, P.E.** 

**11/13/2008**

4 the chrome plating tank and chrome

evaporation unit are operating

simultaneously. A complete report

shall be submitted to the District's

Source Test Manager within 60 days of

the source test and shall demonstrate

compliance wit h Condition 3, above.

5. Parameter Monitoring

a) To demonstrate compliance with

Condition 1, above, RTW shall

install, operate and maintain a

continuous recording, non

- resettable

ampere

- hour meter that operates

on the electrical power lines

connected to the tank rectifier.

A separate meter shall be

hard

- wired for each rectifie r if

applicable.

b) RTW shall continuously monitor

the pressure drop across A1 MAPCO

Enforcer III Scrubber. The gauge

shall be located so that it ca n be

easily visible and in clear sight

of the operation or maintenance

personnel. The pressure drop shall

be maintained within plus or minus

2 inches of water of the value

established during the performance

test to demonstrate compliance with

the emission limitation.

Pressure drop readings shall be

recorded at a frequency of at

least one time per operatin g day.

If the pressure drop is found to lie

outside the range of acceptability

RTW shall cease chrome plating as

soon as practicable and take all

appropriate measures t o either

bring the scrubber operation back

into the range of acceptability or

to otherwise demonstrate compliance

with the emission limitation.

6. Inspection/Maintenance

a) RTW shall perform visual

inspections of the A1 MAPCO

Enforcer III Scrubber at a

frequency of at least one time

per calendar quarter.

This vi sual inspection is to**AN 19110/U.S. Mint (Plant A5474)**

**R E Frazier, P.E.** 

**11/13/2008**

5 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.

b) RTW shall visually inspect the

back portion of the scrubber

closest the stack at a

frequency of at least one time

per quarter to ensure there is no

breakthrough of chromic acid mist.

c) RTW shall visually inspect the

ductwork from tank to the control

device at a frequency of at least

one time per ca lendar quarter to

ensure there are no leaks. In the

event a leak is discovered, it shall

be repaired as soon as practicable.

d) RTW shall perform washdowns of

the Enforcer III Unit at a

frequency as recommended by the

manufacturer.

e) The ampere

- hour meter shall be

installed and maintained as per

manufacturer's recommenda tions.

7. Operation and Maintenance Plan

a) RTW shall prepare an Operation

and Maintenance (O & M) plan.

The plan shall incorporate the

inspection and maintenance

requirements as noted in

Condition 6, above, and shall

include the following elements:

a) a standardized checklist to

document the operation and

maintenance of the source, the

add

- on air pollution control

devices, and the process and

control system monitoring equipment,

and b) procedures to be followed

to ensure that equipment is

properly maintained.

b) O & M plan retention: RTW shall

keep the written operation and

maintenance plan on record after

it is developed to be made

available for District inspection,**AN 19110/U.S. Mint (Plant A5474)**

**R E Frazier, P.E.** 

**11/13/2008**

6 upon request.

c) Changes to the O & M plan: Any

changes made to the O & M Plan

should be documented in an addendum

to the pla n. In addition, RTW

shall keep previous versions of

the O & M Plan on record to be

made available for District

inspection upon request, for a

period of 5 years after each

revision to the plan.

d) Revisions to address breakdowns:

The O & M Plan shall be revised

as necessary to minimize breakdowns.

To satisfy the inspection and

maintenance procedures, RTW may use

applicable standard operating

procedure (SOP) manuals,

Occupational Safety and Health

Administration (OSHA) plans, or

other existing plan s, provided

the alternative plans meet the

requirements of this subsection.

8. Recordkeeping

The following records shall be

kept and maint ained by RTW for

at least five years total; and

at least two years on site.

a) Inspection records for A1 MAPCO

Enforcer III Scrubber: RTW shall

maintain inspection rec ords to

document that the Inspection/

Maintenance requirements and the

O & M Plan as required by

Conditions 6 and 7, above,

respectively have been met. The

record can take the form of a

checklist and should identify

1) the device inspected, 2)

the date and time of the inspection,

3) a brief description of the

working condition of the device

during inspection, 4) maintenance

activities performed on the

components of the air pollution

control system (i.e. ductwork,

filter pad, fan, etc), and 5) any

action taken to correct def iciencies

found during inspection.**AN 19110/U.S. Mint (Plant A5474)**

**R E Frazier, P.E.** 

**11/13/2008**

7 b) RTW shall maintain records to

demonstrate that the inspection

and maintenance requirements of

Condition 6, above, have been

satisfied.

c) Performance test records:

RTW shall maintain test reports

documenting the conditions and

results of all performance tests.

d) Monitoring data records: RTW

shall maintain records of

monitoring data as required

by Conditions 1 and 5, as

follows: 1) monthly and annual

records of ampere

- hour t hroughput,

and 2) records of A1 MAPCO

Enforcer III Scrubber pressure

drop monitoring results.

e) Breakdown records: RTW shall

maintain records of the occurrence,

duration, and cause (if known) and

action taken on each breakdown.

f) Records of excesses: RTW shall

maintain records of exceedances

of: a) the emission limitation

identified in Condition 3; b)

the monitoring parameter values

of Condition 5; c) any site

- specific

operating parameters established

for alternative equipment. The

records sha ll include the date of

the occurrence, the duration, cause

(if known), and where possible,

the magnitude of any excess

emissions.

9. Reporting

a) On an annual basis, RTW shall

prepare a summary report to the

District to document the ongoing

compliance status. This report

shall be made availabl e to the

District upon request.

b) Breakdown reports: RTW shall

report breakdowns as required by

the District breakdown procedures

identified in Regulation 1.**AN 19110/U.S. Mint (Plant A5474)**

**R E Frazier, P.E.** 

**11/13/2008**

8 NEW CONDITION 8641

COND# 8641

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

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 eff ective through 10

- 23

- 2009:

Emissions of hexavalent chromium shall not exceed

0.006 mg per ampere

- hour (mg/amp

- hr) after abatement.

[Basis: 93102.4(a)(1)]

b) Emission Limits eff ective 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 t otal annual throughput shall not

exceed 35 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 provis ions 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/opera tor shall abate at all times during

operation of S

- 1 with plating tank emissions vented

through A

- 1 Mapco Enforcer III Scrubber. All emissions

shell be exhausted at a height of at least 43 feet

(13 meters) above gra de. [Basis: 93102.4(b)]

The ventilation and abatement system shall be properly

maintained and kept in good working condition.

b) The owner/operator uses Fumetrol 140 chemical fume

suppressant bath ad ditive 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 ten siometer.

[Basis: 93102.9(d)(2)]

3. Source Test**AN 19110/U.S. Mint (Plant A5474)**

**R E Frazier, P.E.** 

**11/13/2008**

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

October 24, 2009 to demonstrate compliance w ith 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

schedul e:

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 l ater 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 compli ance.

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

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**AN 19110/U.S. Mint (Plant A5474)**

**R E Frazier, P.E.** 

**11/13/2008**

10 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.

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 S ource 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 platin g 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 wit hin 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 o perator or current

employee who is onsite and has completed the ARB

Compliance Assistance Training Course for chrome

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 c losed

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 sold hexavalent chrome contai ning

material that is spilled shall be contained or

cleaned up within one hour after being spilled.

d) Dragout shall be minimized by:**AN 19110/U.S. Mint (Plant A5474)**

**R E Frazier, P.E.** 

**11/13/2008**

11 i. handling the plated parts so that chromi c 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

sepa rated 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 manufactu rer's specifications. The

owner/operator shall record the total ampere

- hours

used during each month.

[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

Mapco Enforcer III Scrubber. 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 operati ng 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 operati on. If an exceedance**AN 19110/U.S. Mint (Plant A5474)**

**R E Frazier, P.E.** 

**11/13/2008**

12 occurs, the measurement frequency shall return to

daily for 20 operating days, and weekly thereafter.

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

7. Operation & Maintenance (O&M) P lan

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 revisi ons 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, op eration

and maintenance for the chrome plating operation,

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 and conduct wash downs of the

Mapco Enforcer III unit per manufacturer

recommendations. [Basis: 93102.10(a) and Reg 2

- 5]

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

the owner/operator shall record the equipment b eing

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 an y

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.**AN 19110/U.S. Mint (Plant A5474)**

**R E Frazier, P.E.** 

**11/13/2008**

13 b) The owner/operator shall:

[Basis: 93102.12]

i. Record the plating bath surface tension

accordi ng 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 Mapco Scrubber pressure drop

at least once per operating week.

c) Breakdown Records noting the occurrence,

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

d) Records of excesses of the emission or ampere

- hour

li mits 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, inc luding 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)]