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

i nvolved 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 A batement

- 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 Cond itions:**  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 ap plication 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 installat ion 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 f acility 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 dec orativ e 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 0.0 11

Future Emissions 500,000 0.0015 0.00 17

Net Difference 500,00 ( 0 .0085) 0 .0 0 94AN 20571/Cycle Shack (Plant B1496)

RE Frazier, P.E.

04

- 29

- 2009

2 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, therefo re 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 1 6078 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

3 CURRENT CONDITION 16078

C COND# 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 5 00,000 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 met er 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

Sufficien t 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 platin g 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 onc e 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), t he 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 i n 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 recom mendations.

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

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- 2009

4 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 Condi tion 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 suppress ant

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 to tal

throughput of chrome plating operation in ampere

-

hours.

B. Compliance StatusAN 20571/Cycle Shack (Plant B1496)

RE Frazier, P.E.

04

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- 2009

5 The operator of S

- 1 shall annually prepa re 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 Se ction

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://ww w.arb.ca.gov/toxics/atcm/chroatcm.pdf

1. Performance Standards

a. Throughput: The total annual throughput shall not

exceed 5 00,000 ampere

- hours in any consecutive 12

- month

perio d. [Basis: 93102.4(b)(1)]

b. Emission Limits Effective 10

- 24

- 201 1 :

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 suppre ssants,

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

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- 2009

6 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

- 201 1 compliance deadline noted above

in Part 1b of this Condition. [Basis: 9 3102.4(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 individu al(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. Housek eeping

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 li quid 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. handl ing 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 t o the tank.

e) Surfaces within the chrome storage area and theAN 20571/Cycle Shack (Plant B1496)

RE Frazier, P.E.

04

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- 2009

7 walkways and other areas potentially contaminated

with hexavalent chrome, shall be cleaned at least

one time every seven days by ei ther 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 are as 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 maintain ed

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 moni toring: 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 measurem ent 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 yearsAN 20571/Cycle Shack (Plant B1496)

RE Frazier, P.E.

04

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- 2009

8 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

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- 2009

9 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 Additi ve 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 multip lied 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, provi de 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

- appro ved 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

10 By:

Randy E. Frazier, P.E.

Senior Air Quality Engineer

29 April 2009