ENGINEERING EVALUATION REPORT

PLANT NAME Electroforming-Richmond

APPLICATION NUMBER 19118

PLANT NUMBER 5665

DATE 12-3-2008

1. BACKGROUND

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

Chromium Plating and Chromic 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 sources 

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 Control Abatement-1 Abatement-2

1 7623 7623 Any Listed 

Surfactant

In Section

93102.8(a)

Future 

Controls

Future 

Controls

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 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 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 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 less than 330 feet from the nearest sensitive receptor. This facility was 

conditioned to a throughput of 416,000 amp-hr/hr, although they actually use approximately 

115,000 amp-hr/yr. Electroforming has agreed to accept a permit condition limiting them to 

200,000 a-hr/yr with plans to install controls to achieve an emission level of 0.0015 mg/a-hr or less 

by October 24, 2010. Until 2010, Electroforming will operate with the revised throughput as a 

Category 2 facility, required to meet the 0.0015 mg/a-hr limit by October 24, 2010. In early 2010, 

Eletroforming plans to apply for an Authority to Construct/Permit to Operate for a new ventilation 

system and suitable control devices to attain the 0.0015 mg/a-hr limit. Until that time, the facility 

will continue to operate as a conventional decorative chrome plating with approved plating bath 

additives for control. Emission calculations are shown for the various cases:
AN 19118/Electroforming (Plant A5665)

RE Frazier, P.E.

12/3/2008

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Basis Throughput, a-hr/yr Factor, mg/a-hr Emissions, lb/yr

Current 416,000 0.01 0.009

AN 19118 Condition 

Change 

200,000 0.01 0.0044

Net Difference 216,000 0 0.00476

3. CEQA

Since the permitted emission levels decrease, this application is exempt from CEQA review per 

Reg 2-1-312.1.

4. BEST AVAILABLE CONTROL TECHNOLOGY

Emission levels decrease, 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 emission levels decrease, the risk level decreases, therefore no toxic evaluation is 

required. 

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. CONDITIONS

The previous version of Condition 7623 is presented in this application, as is the revised 

condition.. 

10. RECOMMENDATIONS

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

Condition 7623.
AN 19118/Electroforming (Plant A5665)

RE Frazier, P.E.

12/3/2008

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CURRENT CONDITION 7623

COND# 7623 --------------------------------------

 1) Throughput 

 The total annual combined throughput at source S-1 shall

 not exceed 416,000 amp-hrs in any consecutive twelve

 month period. 

 2) Amp-hours of operation 

 To comply with the above condition, Electroforming 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 operation 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 McGean Rohco Atotech TB-11709 wetting-

 agent additive or equivalent with bath surface 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 shall be monitored at a

 frequency of at least one time every 4,000 amp-hours of

 bath operation. 

 If after 40,000 amp-hours of rectifier operation, the

 surface tension monitoring results 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 bath 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 frequency

 can be further reduced to "at least one time every 40,000

 amp-hours of bath operation". 

 5) Surface Tension Monitoring - Testing Methods 

 Surface tension testing shall be conducted 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
AN 19118/Electroforming (Plant A5665)

RE Frazier, P.E.

12/3/2008

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 the method has been appropriately validated using EPA

 Method 301, Appendix A, 40 CFR Part 63. 

 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 

 Electroforming shall keep and maintain the following

 records associated with source S-1: 

 a) Performance test records.

 b) Operating throughput records (monthly, amp-hour

 throughput)

 c) Records of chemical additions to chrome plating bath.

 8) Reporting 

 Electroforming shall provide the BAAQMD with the

 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 

 Electroforming 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 7623

 COND# 7623 --------------------------------------

 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
AN 19118/Electroforming (Plant A5665)

RE Frazier, P.E.

12/3/2008

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 1. Performance Standards 

 a. Throughput: The total annual throughput shall not

 exceed 200,000 ampere-hours in any consecutive 12-month

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

 b. Emission Limits Effective 10-24-2010:

 Emissions of hexavalent chromium shall not exceed

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

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

 2. Abatement 

 a. Surface Tension: The owner or operator shall control

 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 Chemical LLC) 

 b. Add-On Control Equipment: The owner or operator shall

 apply for and obtain an Authority to Construct for add-on

 hexavalent chrome ventilation and abatement equipment in

 advance of the 10-24-2010 compliance deadline noted above

 in Part 1b of this Condition. [Basis: 93102.4(b)] 

 3. 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 pertaining to

 chrome plating and chrome anodizing.
AN 19118/Electroforming (Plant A5665)

RE Frazier, P.E.

12/3/2008

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 [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 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 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. 

 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/operator shall record the total ampere-hours

 used during each month.

 [Basis: 93102.9(a), 93102.12(c)(1)] 
AN 19118/Electroforming (Plant A5665)

RE Frazier, P.E.

12/3/2008

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 b) Surface Tension monitoring: In order to

 demonstrate compliance with part 2, above, the

 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 measurement

 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 weekly

 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 written

 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 

 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] 
AN 19118/Electroforming (Plant A5665)

RE Frazier, P.E.

12/3/2008

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 i. Record the plating bath 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 of

 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 source 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 maintenance 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
AN 19118/Electroforming (Plant A5665)

RE Frazier, P.E.

12/3/2008

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 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: 

 Title: 

 Date:

By:

Randy E. Frazier, P.E.

Senior Air Quality Engineer

2 December 2008