ENGINEERING EVALUATION REPORT

PLANT NAME Electrocoatings of Berkeley

APPLICATION NUMBER 14348

PLANT NUMBER 4449

DATE 3 July 2006

1. BACKGROUND

Electrocoatings (ECI) of Berkeley has filed this application to replace their current chrome plating scrubber 

system A-5 with individual high efficiency Scrubair component abatement devices for each chrome-plating 

tank. In addition, ECI plans to discontinue the use of foam bath additive in sources S-4 and S-8. ECI is 

currently conditioned to a maximum emission factor of 0.0061 mg/a-hr. This application/evaluation 

assumes the same level of control. Accordingly, the sources will change as follows:

S-2 Hard Chrome Plating Bath - Tank #3 Abated by A-6 3-Stage ScrubAir System

S-4 Hard Chrome Plating Bath w/Foam - Tank #7 Abated by A-7 3-Stage ScrubAir System

S-8 Hard Chrome Plating Bath w/Foam - Tank #1 Abated by A-8 3-Stage ScrubAir System

Although the new scrubber units are expected to achieve an emission control level equivalent to the old 

system, certain changes will occur in the exhaust parameters. In addition, the District has learned that the 

block kitty-corner to the ECI facility has been rezoned mixed use-commercial and residential. These 

changes are expected to impact the exposure levels in the area around ECI. This is important information 

to consider, since the current amp-hr throughput condition coupled with the 0.0061 mg/a-hr emission factor 

is based on the maximum risk level of 9.9 in a million--which was based on the previous health risk 

assessment conducted for AB-2588 in the 1990s.

Therefore a new health risk assessment will be performed for ECI. The amp-hr throughput will be adjusted 

to maintain a maximum risk of 9.9 in a million.

2. EMISSION CALCULATIONS

Hex Chrome Emissions = (23,000,000 amp-hr/yr)(0.0061 mg/amp-hr)(lb/454E3mg) = 0.309 lb/yr

Additional detail on the 23E6 amp-hr and emission factor basis are provided in Appendix 2 and in the Toxic 

Evaluation Section

3. TOXIC EVALUATION

Based on the above emissions of chrome, the carcinogenic and chronic risks were estimated for the 

maximally exposed residential and industrial receptors. All stack emissions are exhausted vertically - 55 ft 

above ground level. Modeling runs were conducted for both ground level and elevated receptor @ both 

urban and rural land use parameters. The highest result was used as the basis for the risk screen, and 

hence for calculating the resulting amp-hour limit.

Modeling parameters are presented in Table 1 as well as Appendix 1 and risk calculations spreadsheet is 

presented in Appendix 3. The emissions basis spreadsheet is shown as Appendix 2. The modeling was 

performed using ISCST3 (BEEST) with source file inputs including the appropriate health potency factors, 

emission rates and unit conversions resulting in model outputs in units of risk in a million or hazard quotient. 

Table 3 presents a matrix showing the modeling runs, which were completed for this analysis.
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TABLE 1 RISK MODELING PARAMETERS

PARAMETER S-2, S-4, S-8 Chrome Plating Tanks

Met Data OST002.asc (EDMUD Sewage Trmt Plant)

Exhaust Velocity 5000 fpm (83.3 ft/sec)

Stack Height 55’ 

Chrome Amp-Hours, annual 23 E 6

Chrome Emission Factor 0.0061 mg/a-hr

Chrome Emissions 0.309 lb/yr

TABLE 2 WORST CASE TOXIC RISK SUMMARY

RISK TYPE Cancer Risk

(X 1E-06)

Chronic,

Non-Cancer

Residential 9.9 0.00032

Worker 7.4 0.00029

TABLE 3 MODELING SUMMARY MATRIX

CASE Residential

Exposure, 

μg/cu me per g/s

Industrial

Exposure

μg/cu me per g/s

Elevated Receptor (16’)

 Urban Terrain 14.52 13.11

 Rural Terrain 6.83 5.44

Ground Level Receptor

 Urban Terrain 14.04 12.23

 Rural Terrain 6.30 4.28

The residential cancer risk is less than 10 in a million. The cancer risk level for worker exposures are also 

less than 10 in a million—which is an acceptable level with the application of TBACT controls. A controlled 

emission factor of 0.0061 has been determined to represent TBACT for a facility of this size. This is the 

current emission factor, which the facility is conditioned to meet. The currently conditioned annual 

throughput will be reduced from 38.6 million amp-hours per year to 23 million amp-hours per year, to keep 

the maximum risk less than 10 in a million.

Chronic non-cancer risks are well within acceptable levels.

5. PERMIT REQUIREMENTS/DISCUSSION OF EXEMPTION

Not applicable.

6. DETERMINATION OF COMPLIANCE

A. Regulation 1 – General Provisions and Definitions

§1-301: Prohibits discharging emissions in quantities that cause injury, detriment, 

nuisance, or annoyance. The toxic evaluation addresses these issues. 

B. Permits – General Requirements, Regulation 2 Rule 1

The source is not located within 1000 feet of the nearest school, and is therefore not 

subject to the public notification requirements of 2-1-412.

C. Permits – New Source Review, Regulation 2 Rule 2 (dated 10/7/98)
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1. BACT: The chrome control device that is being installed represents BACT for a 

facility of this size, guaranteed to achieve a maximum emission level of 0.0061 

mg/amp-hr. .

2. Offset Requirements: §2-2-303: Offsets are not applicable to this project.

3. Prevention of Significant Deterioration: §2-2-304: PSD requirements are not 

applicable.

D. Regulation 3 – Fees

ECI has complied with the fee requirements for this loss of exemption permit application.

E. Particulate Matter and Visible Emissions, Regulation 6

1. Section 301 prohibits for more than 3 minutes per hour, visible emissions as 

dark or darker than Ringelmann 1 or equivalent opacity. Visible emissions have 

never been an issue at this facility. No change is expected.

2. Section 305 prohibits emissions of visible particles from causing a nuisance on 

property other than the operators. The aforementioned sources have never 

created a nuisance and with the expected reduced emissions are not expected 

to create a nuisance in the future.

3. Section 310 limits the particulate concentration in exhaust gases to 0.15 gr/dscf. 

At an exhaust rate well over 15,000 cfm and an annual chrome emission of 

approximately 0.3 lb/year we expect these sources will have no difficulty in 

complying with the emission limitations of 6-310.

F. NSPS/NESHAPS

The chrome plating ATCM has been granted equivalency with the Federal NESHAP. This 

plating operation complies with the chrome ATCM.

G. CEQA

This project is considered to be ministerial under the District’s CEQA Regulation 2-1-311. 

The engineering review for this project requires only the application of standard permit 

conditions and standard emissions factors and therefore is not discretionary as defined by

CEQA. 

7. CONDITIONS

Recommend the following conditions for the following sources:

S-2 Hard Chrome Plating Bath - Tank #3 Abated by A-6 3-Stage ScrubAir System

S-4 Hard Chrome Plating Bath w/Foam - Tank #7 Abated by A-7 3-Stage ScrubAir System

S-8 Hard Chrome Plating Bath w/Foam - Tank #1 Abated by A-8 3-Stage ScrubAir System

1. Annual Usage

The total annual (net) throughput from the combined sources S-2, S-4, and S-8 shall not exceed 

23 million ampere-hours in any consecutive twelve-month period. (Basis: Regulation 2-5, Toxics 

NSR)

2. Abatement

Source S-2 shall not be operated unless all emissions are vented through A-5 Three Stage High 

Efficiency Fiberbed Mist Elimination System. The ventilation and abatement system shall be 

properly maintained and kept in good operating condition.
Electrocoatings Inc.

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Exhaust emissions from plating tanks S-2, S-4 and S-8 shall be vented, respectively, through A-6, 

A-7, and A-8 Three Stage ScrubAir System(s). The ventilation and abatement system shall be 

properly maintained and kept in good operating condition. (Basis: Regulation 2-5, Toxics NSR)

3. Emission Limits

Emissions of hexavalent chromium from A-5 shall not exceed 0.0061 milligram per ampere-hour 

(mg/a-hr) after abatement. (Basis: Regulation 2-5, Toxics NSR)

4. Source Test

Biennial Source Test: To assist in demonstrating ongoing compliance with permit condition 3 

above, ECI 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. The initial source test to 

demonstrate compliance with Part 3, shall be conducted within 60 days of initial startup of the 

respective scrubAir System.

Source Testing Protocol: A written source test protocol shall be submitted for District approval 

prior to conducting any source test for compliance. The chrome testing protocol shall include a 

requirement to operate all chrome plating baths at normal rectifier amperages during the test 

period. This source test protocol shall include testing methods, length of sample period, plating 

facilities to be operating during the source test, parameters to be monitored, 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. 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, ECI shall install, operate and maintain 

continuous recording, non-resettable ampere-hour meters that operate on the electrical 

power lines connected to the tank rectifiers. A separate meter shall be hard-wired, 

maintained and operated for each rectifier if applicable.

b) In order to comply with Regulation 11 Rule 8, Section (e)(2) and (e)(3) ECI shall determine 

and recommend a parameter for regular monitoring to ensure ongoing compliance with part 

4, above. The initial source test shall be used to establish the parameter operating range.

This parameter type as well as an initial parameter operating range will be added to this part 

as an administrative amendment, upon demonstration of compliance with part 4.

6. Inspection/Maintenance

a) ECI shall perform visual inspections of the ScrubAir systems A-6, A-7, and A-8 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) ECI 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) ECI 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) ECI shall perform periodic wash downs of the ScrubAir systems at a frequency as 

recommended by the manufacturer.
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c) The ampere-hour meter shall be installed and maintained as per manufacturer’s 

recommendations.

7. Operation and Maintenance Plan

a) ECI shall revise the operation and maintenance (O & M) plan. The plan shall incorporate the 

inspection and maintenance requirements as noted in Part 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.

b) O & M plan retention: ECI shall keep the written operation and maintenance plan on record 

and 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, ECI 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 years 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, ECI 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 ECI for at least five years total; and at least 

two years on site.

a) Inspection records for A-6, A-7, and A-8 ScrubAir Systems: ECI shall maintain inspection 

records to document that the Inspection/Maintenance requirements and the O & M Plan as 

required by Parts 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 and 

any action taken to correct deficiencies found during inspection.

b) ECI shall maintain records to demonstrate that the inspection and maintenance requirements 

of Part 6, above, have been satisfied.

c) Performance test records: ECI shall maintain test reports documenting the conditions and 

results of all performance tests.

d) Monitoring data records: ECI shall maintain records of monitoring data as required by Parts 1 

and 5.

e) Breakdown records: ECI shall maintain records of the occurrence, duration, and cause (if 

known) and action taken on each breakdown.

f) Records of excesses: ECI shall maintain records of exceedances of: a) the emission 

limitation identified in Part 3; b) the monitoring parameter values of Part 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.
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9. Reporting

a) On an annual basis, ECI shall prepare a summary report to the District to document the 

ongoing compliance status. This report shall be kept on site and made available to the District 

upon request.

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

procedures identified in Regulation 1.

8. RECOMMENDATIONS

Issue permit to operate for hard chrome plating tanks S-2, S-4, and S-8 subject to Condition # 23126.

By:

Randy E. Frazier, P.E.

Senior Air Quality Engineer

3 July 2006