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 B ath 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:** Exc ept 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 w hich 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 devi ces 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 f acility 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 50 0,000 0.01 0.011

Post

- ATCM 50,000 0.01 0.0011

Net Difference 450,000 0 0 .00 99AN 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 signific ant 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 fe et 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 2044 0

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

Th e 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 suppressan t

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 viola tion 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

4 5. Inspection/Maintenance

a) The ampere

- hour meter shall be instal led 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, an d 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 t he 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 Di strict 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. Th is

report shall be made available to the District

upon request.

c) Breakdown reports: Santa Rosa/Carrera Plating

shall report breakdowns as required by the

Di strict 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 t he 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: 931 02.4(b)(1)]

2. Abatement

Surface Tension: The owner or operator shall control

hexavalent chrome emissions by the use of one of the

following CARB

- ap proved 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: 93 102.8(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/record keeping) 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

fugi tive 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) Dr agout 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

minim ize 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 hexavale nt 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 fu gitive dust.

5. Monitoring

a) Each rectifier shall be hard

- wired to a single non

- resettable meter which records ampere

- hours

continuously during rectifie r 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.

[Basi s: 93102.9(a), 93102.12(c)(1)]

b) Surface Tension monitoring: In order toAN 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 2 0 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 we ek 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 Tensi on 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, o r 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 chro me 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 peri od 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 mete r(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 cor rect 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 actio ns.

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 & Pla nt 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 Limi t:

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 hex avalent 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 follow ed

(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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