ENGINEERING EVALUATION REPORT

PLANT NAME Cycle Shack, Inc

APPLICATION NUMBER 20571

PLANT NUMBER 11496

DATE 4-29-2009

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 16078 16078 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:

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. This facility was 

conditioned to a throughput of 500,000 amp-hr/hr. This places the facility in Category 3, with the 

requirement to demonstrate 0.0015 mg/a-hr by October 24, 2011 Prior to this date Cycle Shack 

will need to apply for an authority to construct/permit to operate the ventilation system and 

abatement system to attain the above standard. Until that time, the facility will continue to operate 

as a conventional decorative chrome plating with approved plating bath additives for control. 

Emission calculations are shown for the various cases:

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

Current 500,000 0.01 0.011

Future Emissions 500,000 0.0015 0.0017

Net Difference 500,00 (0.0085) 0.0094
AN 20571/Cycle Shack (Plant B1496)

RE Frazier, P.E.

04-29-2009

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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 TECHNOLOGY

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 16078 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 

Condition 16078.
AN 20571/Cycle Shack (Plant B1496)

RE Frazier, P.E.

04-29-2009

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CURRENT CONDITION 16078

CCOND# 16078 --------------------------------------

 Ap. 17678; Pl. 11496; S-1 Hex Chrome Bath 

 1. Throughput 

 The total actual cumulative rectifier usage at source

 S-1 shall not exceed 500,000 amp-hrs in any consecutive

 twelve month period. 

 2. Amp-hours of operation 

 To comply with the above condition, the operator of

 this source shall keep and maintain monthly records of

 current applied to this source integrated over time, in

 units of ampere-hours. These Ampere-hour records shall

 be monitored using a non-resettable amp-hour meter.

 Ampere-hour meter shall 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 

 Sufficient mist suppressant (Fumetrol 140 Mist

 Suppressant additive or equivalent) shall be maintained

 in the chrome plating tank (S-1) to produce a surface

 tension of 45 dynes per centimeter or less at all times

 while plating is in progress. 

 4. Surface Tension Monitoring - Frequency 

 To demonstrate compliance with condition 3 above, the

 surface tension of source S-1 shall be monitored at

 least once each operating day for 20 consecutive

 operating days. Provided the surface tension

 monitoring results indicate no exceedances of the

 maximum surface tension standard identified in

 Condition 3 above (45 dyne/cm), the monitoring

 frequency may be reduced to weekly (at least once each

 6 days of bath operation). 

 5. Surface Tension Monitoring - Testing Methods 

 Surface tension shall be measured in dynes per

 centimeter in accordance with EPA Method 306-B by the

 use of a stalagmometer or preciser tensiometer. The

 operator of source S-1 shall inspect and maintain the

 instrument according to manufacture's recommendations.

 7. Inspection and Maintenance Recordkeeping 

 The operator of this source shall maintain the

 following records associated with operation of S-1: 
AN 20571/Cycle Shack (Plant B1496)

RE Frazier, P.E.

04-29-2009

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 A. Surface Tension Monitoring 

 A daily record shall be kept and maintained on

 site of surface tension measurements for the first

 20 days of operation. If there are no exceedances

 of the standard identified in Condition 3 above

 (45 dyne/cm), thereafter a weekly record shall be

 kept and maintained of surface tension. These

 records shall also contain any maintenance

 activities performed on the stalagmometer/

 tensiometer, and any actions taken to correct

 deficiencies found during the monitoring event. 

 B. Amp-hours of operation 

 The actual cumulative rectifier usage shall be

 recorded for each month of operation (monthly amp-

 hour throughput) and totaled annually. 

 C. Fume Suppressant Additions 

 Records shall be maintained of fume suppressant

 additions including the date, time, approximate

 volume, and product identification of the fume

 suppressants that are added to the electroplating

 bath. 

 D. Records of Excess Emissions 

 Any exceedance of the standard identified in

 Condition 3 above (45 dyne/cm), or the throughput

 limit identified in Condition 1 above (500,000

 amp-hours/yr), shall be recorded on the day that

 it is first discovered. The records shall include

 the date of the occurrence, the duration, and

 cause (if known) of any exceedance. 

 E. Retention of Records 

 All records required by this condition shall be

 maintained for a period of five years, and shall

 be kept on site for a period of two years. 

 8. Reporting 

 A. Annual Throughput 

 The operator of S-1 shall submit to the District

 through the annual update program, the total

 throughput of chrome plating operation in ampere-

 hours. 

 B. Compliance Status 
AN 20571/Cycle Shack (Plant B1496)

RE Frazier, P.E.

04-29-2009

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 The operator of S-1 shall annually prepare and

 make available to the District upon request a

 summary report documenting the ongoing compliance

 status of the source. The report shall contain the

 information identified in Appendix 3 of Section

 93102, Title 17 of the California Code of

 Regulations.

NEW CONDITION 16078

 COND# 16078 --------------------------------------

 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 

 a. Throughput: The total annual throughput shall not

 exceed 500,000 ampere-hours in any consecutive 12-month

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

 b. Emission Limits Effective 10-24-2011:

 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 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.) 
AN 20571/Cycle Shack (Plant B1496)

RE Frazier, P.E.

04-29-2009

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 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 10-24-2011 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 the ARB

 Compliance Assistance Training Course pertaining to

 chrome plating and chrome anodizing.

 [Basis: 93102.5(b)] 

 Chrome plating operations during physical absence of the 

 trained owner or operator are permissible as long as the

 trained individual(s) are physically based at the facility

 and are directly involved with the day to day environmental

 practices and requirements associated with the chrome plating

 operation. 

 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
AN 20571/Cycle Shack (Plant B1496)

RE Frazier, P.E.

04-29-2009

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 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

 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
AN 20571/Cycle Shack (Plant B1496)

RE Frazier, P.E.

04-29-2009

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 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] 

 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:
AN 20571/Cycle Shack (Plant B1496)

RE Frazier, P.E.

04-29-2009

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 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. 

 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:
AN 20571/Cycle Shack (Plant B1496)

RE Frazier, P.E.

04-29-2009

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By:

Randy E. Frazier, P.E.

Senior Air Quality Engineer

29 April 2009