ENGINEERING EVALUATION REPORT

PLANT NAME Roll Technology West

APPLICATION NUMBER 19717

PLANT NUMBER A7546

DATE April 28, 1999

1. BACKGROUND

This application is for a change of condition # 8641 for the following source at Roll Technology West 

(RTW) in Pittsburg:

S-1 Hard Chrome Plating Tank

Currently this source is permitted for a chrome throughput of 19.2 million amp-hours per year (12-month 

basis). The emission factor is currently conditioned to 0.012 mg/a-hr. In 1996 RTW demonstrated an 

emission factor of 0.004 mg/a-hr total chrome and <0.00091 mg/a-hr hex chrome. The 1998 source test 

demonstrated an emission factor of 0.0022 mg/a-hr. Conservatively, it appears RTW will be able to achieve

an actual emission rate of 0.004 mg/a-hr on a consistent basis.

RTW desires to increase their chrome plating tank throughput to 35 million amp-hours per year (12-month 

basis). This application will evaluate this increase in light of existing Regulation 11-8, the new State 

ATCM, the federal NESHAP as well as the previous AB-2588 health risk assessment. For the purposes of 

current permit requirements, the new State ATCM has been deemed to be equivalent (or more stringent) to 

the Federal chrome plating NESHAP. Hence, compliance with the State ATCM (District regulation 11 

Rule 8) will ensure compliance with the Federal NESHAP. Permit conditions will be revised accordingly.

The source will hereafter be more clearly identified as:

S-1 Hard Chrome Plating Tank Abated by A1 Trimer ChromeScrub Unit, 6-Stage, 

12,000 CFM

For the purposes of Regulation 11 Rule 8, this permit application amounts to a modification, and will be 

subject to the permitting and operating requirements of modified hard chrome plating sources.

2. EMISSION CALCULATIONS

S1 Chrome Plating Bath Abated by A1 High Efficiency ChromeScrub Unit, 12,000 CFM

RTW applied for a throughput increase to 35 MM a-hr/yr. Emissions will change according the following 

parameters.

• Current Maximum Hex Chrome Emissions = [19,200,000 ampere-hours/yr]*[0.012 mg hex 

chrome/ampere-hour)/[454,000 mg/lb] =0.507 lb/yr

• Proposed Maximum Hex Chrome Emissions = [35,000,000 ampere-hours/yr]*[0.006 mg hex 

chrome/ampere-hour)/[454,000 mg/lb] = 0.46 lb/yr
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• Estimated Actual Chrome Emissions = [35,000,000 amp-hr/yr]*[0.004 mg/a-hr]/454E3 mg/lb 

= 0.31 lb/yr

3. PERMIT REQUIREMENTS/DISCUSSION OF EXEMPTION

RTW is required to comply with BAAQMD Regulation 11-8 for chrome, Reg 2-1-316 (New or Modified 

Sources of Toxic Air Contaminants), the Federal Chrome Plating NESHAP. In November, 1998, Reg 11-8 

was amended to adopt the State ATCM by reference. At this time, there are no exemptions associated with 

this source. Since this application is for an increase in the permitted throughput, this application is defined 

as a modification and will be subject to the appropriate requirements.

4. BEST AVAILABLE CONTROL TECHNOLOGY

Regulation 11 Rule 8 represents TBACT for chrome plating facilities. The specific requirement for this 

modified chrome plating facility is a controlled outlet emission factor of 0.03 mg/a-hr. A source test 

conducted in 1996 demonstrated a hex chrome emission factor of 0.004 mg/a-hr total chrome and <0.00091 

mg/a-hr. A July, 1998 source test demonstrated a hex chrome emission factor of 0.0022 mg/a-hr. Since the 

demonstrated emission factor is well below the TBACT emission factor we conclude that RTW meets the 

criteria of TBACT for this source.

This source will be subject to the following specific requirements of Reg 11-8:

Maximum emission factor (per 11-8): <0.03 mg/a-hr (c)(1)(B)

Use of existing performance test: Normally the District would choose to accept a previous source test to 

demonstrate compliance as long as the source test was approved by the District and the US EPA. RTW is 

required to conduct ongoing source tests at a frequency of at least every 24 months. This requirement will 

not change.

Parameter Monitoring:

(e)(1) Ampere-hours

(e)(2) Pressure drop

Inspection and Maintenance:

(f)(1) Visual inspections @ frequency + washdown of the mist eliminator system as per mfr. 

recommendations + a-hr meter—per mfr. instructions.

Operation and Maintenance Plan

(g)(1) Preparation of O&M plan

(g)(2) Retain the O&M plan

(g)(3) Changes to the O&M plan

(g)(4) Revisions to address breakdowns

Recordkeeping

(h)(1) Inspection records- add-on pollution control devices

(h)(3) Performance test records

(h)(4) Monitoring data records

(h)(5) Breakdown records

(h)(6) Records of excesses

(h)(7) Records demonstrating facility size

(h)(11) Records retention

Reporting

(i)(3)(A)(2) Ongoing compliance (content identified on Appendix 3)

(i)(4) Reports of breakdowns
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5. OFFSETS

Offsets are not applicable in this permit application.

6. TOXIC EVALUATION

A risk evaluation was performed for RTW by Chemical Data Management Systems for AB-2588. Based on 

the AB-2588 health risk analysis the current risk posed at the permitted hex chrome emission level (0.507 

lb/yr) is 2.8/MM for the residential MEI and 5.2/MM for the industrial MEI.

The modified emission level of 0.46 lb/yr will result in the toxic cancer risk decreasing to 2.5/MM for the 

residential MEI and 4.7/MM for the industrial MEI. This application complies with the requirements of 

District toxic risk policy.

7. STATEMENT OF COMPLIANCE

This source complies with District Regulation 2-1-316 for air toxic contaminants as well as Regulation 11-8 

for the control of emissions from hard chrome plating operations. The existing permit condition 8641 will 

be modified to meet these requirements as well as to adjust the maximum throughput to allow 35 MM ahr/yr (12 month basis).

8. CONDITIONS

Recommend accepting the revised Condition 8641 to bring the requirements for this source up to 

date with District/State and Federal regulations.

Also recommend changing the source description to:

S1 Hard Chrome Plating Tank Abated by Trimer ChromeScrub Unit, 6 

Stages, 12,000 cfm

1. Annual Usage

The total annual (net) throughput from chrome plating tank S1 shall not exceed 35 million amperehours in any consecutive twelve-month period.

2. Abatement

This source shall not be operated unless all chrome plating tank emissions are vented through A1 

Trimer ChromeScrub 6-Stage Unit. All emissions shall be exhausted at a height 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.
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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 

equipment and methods, as well as the planned date for the source test.

All source tests used to demonstrate compliance shall determine 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 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 with 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 

rectifier if applicable.

b) RTW shall continuously monitor the pressure drop across A1 Trimer ChromeScrub Unit. 

The gauge shall be located so that it can be easily visible and in clear sight of the operation 

or maintenance personnel. The pressure drop shall be maintained within plus or minus 1 inch 

of water of the value established during the performance test to demonstrate compliance with 

the emission limitation. 

6. Inspection/Maintenance

a) RTW shall perform visual inspections of the A1 ChromeScrub Unit at a frequency of at least 

one time 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.

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 ductwork from tank to the control device at a frequency of at 

least one time per calendar 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 ChromeScrub Unit at a frequency as recommended by 

the manufacturer

e) The ampere-hour meter shall be installed and maintained as per manufacturer’s 

recommendations.

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 ad 

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.
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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, upon request.

c) Changes to the O & M plan: Any changes made to the O & M Plan should document in an 

addendum to the plan. 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 year 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 plans, provided the alternative plans meet the requirements of this 

subsection.

8. Recordkeeping

The following records shall be kept and maintained by RTW for at least five years total; and at 

least two years on site.

a) Inspection records for A1 Trimer ChromeScrub Unit: RTW shall maintain inspection 

records 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 deficiencies found during 

inspection.

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:

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 

shall 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 available to the District upon request.

b) Breakdown reports: RTW shall report breakdowns as required by the District breakdown 

procedures identified in Regulation 1.
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9. RECOMMENDATIONS

Modify Condition 8641for source S1 at Roll Technology West (RTW) and re-issue/include in revised 

Permit to Operate for S1.

by:

Randy E. Frazier, P.E.