ENGINEERING EVALUATION REPORT

PLANT NAME Santa Rosa/Carrera Plating

APPLICATION NUMBER 19121

PLANT NUMBER B4845

DATE 11-13-2008

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 20440 24179 Any Listed 

Surfactant

In Section

93102.8(a)

n/a 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 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 more than 330 feet from the nearest sensitive receptor. The ATCM allows 

facilities to operate at throughputs up to 50,000 amp-hr/yr using only a surfactant, if the facility is 

located more than 330 feet from the nearest sensitive receptor. This facility was previously 

conditioned to a throughput of 500,000 amp-hr/hr, but has accepted a revised condition limit of 

50,000 amp-hr.

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

Current 500,000 0.01 0.011

Post-ATCM 50,000 0.01 0.0011

Net Difference 450,000 0 0.0099
AN 19121/Santa Rosa/Carrera Plating (Plant B2845)

RE Frazier, P.E.

11/13/2008

2

3. CEQA

Since there is no increase in the permitted emission levels, this application is exempt from CEQA 

review per Reg 2-1-312.1.

4. BEST AVAILABLE CONTROL TECHNOLOGY

There is no increase in emission levels, therefore BACT is not applicable.

5. EXEMPTIONS

There are no applicable exemptions.

6. OFFSETS

Offsets are not applicable, since emissions do not increase, therefore no offset triggers are 

exceeded.

7. TOXIC EVALUATION

Emission 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. A previous risk evaluation showed risks to the MEI were less than 

10 in a million. Since the risk was not found to be significant when the emissions were 0.011 lb/yr, 

we do not expect any increased risk at 0.0011 lb/yr.

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 Condition 20440 is presented in this application, as is the new Template Condition 

24179. Condition 24179 is written in general terms for any facility located more than 330 feet from 

any sensitive receptor, with permitted throughput of less than or equal to 50,000 amp-hr/yr.

10. RECOMMENDATIONS

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

Condition 24179.

OLD CONDITION 20440

 COND# 20440 --------------------------------------
AN 19121/Santa Rosa/Carrera Plating (Plant B2845)

RE Frazier, P.E.

11/13/2008

3

 S-1 Decorative Chrome Plating Tank, Abated by

 Wetting Agent Bath Additive, 2000 Ampere Rectifier 

 1. Throughput 

 The total annual throughput from chrome plating

 tank S-1 shall not exceed 500,000 ampere-hours

 in any consecutive twelve-month period.

 [Basis: Cumulative Increase) 

 2. Amp-hours of operation 

 To comply with the above condition, Santa Rosa/Carrera

 Plating shall keep and maintain monthly records of

 current applied to this source integrated over time,

 in units of ampere-hours. Ampere-hours to be monitored

 using a non-resettable amp-hour meter. The Amp-hour

 meter shall be installed in such a manner so as to

 prevent the operation of the bath rectifier without

 the simultaneous operation of the amp-hour meter.

 [Basis: Regulation 11-8 (e)(1)] 

 3. Abatement - Plating Bath Surface Tension 

 Source S-1 shall not be operated unless the plating

 bath is operated with Fumetrol mist suppressant

 additive or equivalent in a quantity sufficient

 to maintain a bath surface tension of 45 dyne/cm

 or less. Santa Rosa/Carrera Plating shall keep

 a record of all suppressant chemical added to

 the bath. [Basis: Regulation 11-8 (c)(2), (h)(8)] 

 4. Surface Tension Monitoring 

 To demonstrate compliance with Condition 3,

 above, Santa Rosa/Carrera Plating shall monitor

 the surface tension of source S-1 at the following

 frequencies: [Basis: Regulation 11-8 (e)(4)] 

 a) The surface tension shall be monitored on a

 daily basis for the first 20 days of bath

 operation after the issuance of this permit.

 Santa Rosa/Carrera Plating shall keep records

 of all surface tension tests, measurements,

 calculations. 

 b) After the first 20 operating days, if there is

 no violation of the surface tension standard

 of part 3, above, the frequency may be decreased

 to at least once per calendar week of operation.

 If a violation occurs, Santa Rosa Carrera Plating

 shall return to a daily monitoring basis for 20

 operating days and weekly thereafter.

 [Basis: Regulation 11-8 (e)(4)] 
AN 19121/Santa Rosa/Carrera Plating (Plant B2845)

RE Frazier, P.E.

11/13/2008

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 5. Inspection/Maintenance 

 a) The ampere-hour meter shall be installed and

 maintained as per manufacturer's specifications. 

 b) The stalagmometer or tensiometer shall be

 calibrated and maintained per manufacturer's

 specifications. [Basis: Regulation 11-8 (f)(2)] 

 6. Operation and Maintenance Plan 

 Santa Rosa/Carrera Plating shall prepare an

 operation and maintenance (O & M) plan. The plan

 shall incorporate the requirements noted in parts

 1- 5, above, and shall include the following

 elements: 

 a) a standardized checklist to document the

 operation and maintenance of the source and 

 b) procedures to be followed to ensure the

 equipment is properly maintained. 

 c) O & M plan Retention: Santa Rosa/Carrera Plating

 shall keep the written operation and maintenance

 plan on record after it is developed to be

 made available for District inspection, upon

 request. 

 d) Changes to the O & M plan: Any changes made to

 the O & M Plan should document in an addendum

 to the plan. In addition, Santa Rosa/Carrera

 Plating 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. 

 7. Reporting 

 a) On an annual basis, Santa Rosa/Carrera Plating

 shall report the chrome plating tank throughput

 on an ampere-hour basis via the District Annual

 Update program. 

 b) On an annual basis, Santa Rosa/Carrera Plating

 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. 

 c) Breakdown reports: Santa Rosa/Carrera Plating

 shall report breakdowns as required by the

 District breakdown procedures identified in

 Regulation 1. [Basis: Regulation 11-8 (i)]
AN 19121/Santa Rosa/Carrera Plating (Plant B2845)

RE Frazier, P.E.

11/13/2008

5

NEW CONDITION 24179

COND# 24179 --------------------------------------

 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

 1. Performance Standards 

 Throughput: The total annual throughput shall not

 exceed 50,000 ampere-hours in any consecutive 12-month

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

 2. Abatement 

 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) 

 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.

 [Basis: 93102.5(b)] 
AN 19121/Santa Rosa/Carrera Plating (Plant B2845)

RE Frazier, P.E.

11/13/2008

6

 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)] 

 b) Surface Tension monitoring: In order to
AN 19121/Santa Rosa/Carrera Plating (Plant B2845)

RE Frazier, P.E.

11/13/2008

7

 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 19121/Santa Rosa/Carrera Plating (Plant B2845)

RE Frazier, P.E.

11/13/2008

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 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

 report required by Part 6(a) of this Condition. 
AN 19121/Santa Rosa/Carrera Plating (Plant B2845)

RE Frazier, P.E.

11/13/2008

9

 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:

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