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 s ources

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 C ontrol 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:

**Permi t 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 per mit 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 ins tallation 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 t o 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 dec orative 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**

2 Basis Throughput, a

- hr/yr Factor, mg/a

- hr Emissions, lb/yr

Curre nt 416 ,000 0.01 0.009

AN 19118 Condition

Change 2 0 0 ,000 0.01 0.00 4 4

Net Difference 216,000 0 0 .0 0476

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 TEC HNOLOGY

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

Cond ition 7623

.**AN 19118/Electroforming (Plant A5665)**

**RE Frazier, P.E.**

**12/3/2008**

3 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 maintai n 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

S ource 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

- ho urs of

bath operation.

If after 40,000 amp

- hours of rectifier operation, the

surface tension monitoring results indicate no

exceedances of the maximum surface ten sion 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 monitori ng 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**

4 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

Electroformi ng 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

- ho urs: 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

requ ired 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/oper ator 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**

5 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 tens ion 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 th e ARB

Compliance Assistance Training Course pertaining to

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

**RE Frazier, P.E.**

**12/3/2008**

6 [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

con tainer 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

mate rial 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 with in 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 w iping, 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 housekeepin g activities shall be

stored, disposed of, recovered, or recycled using

practices that minimize fugitive dust.

5. Monitoring

a) Each rectifier shall be ha rd

- 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**

7 b) Surface Tension monitoring: In order to

demonstrate compl iance 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 operat ing 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 fo r 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) 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

chrome plating bath, amp

- hr meter(s)/totalizers,

stalagmometer or tensiometer. [Basis: 93102.11]

b) A checklist to document the inspecti on, 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 demonstr ate 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**

8 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 total s.

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) Rep orting

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 am pere

- 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 p eriod? Yes No

(circle the appropriate choice)

If yes, provide a description of the changes.

Certifications:

1) I (name and title) certify that th e

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**

9 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