ENGINEERING EVALUATION REPORT

PLANT NAME United Airline-MOC

APPLICATION NUMBER 19105

PLANT NUMBER 51

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

16 23542 23542 none A-216 A-416

17 23542 23542 None A-217 “

18 23542 23542 None A-218 A-418

19 23542 23542 None A-219 “

20 23542 23542 None A-220 A-420

21 23542 23542 None A-221 “

22 23542 23542 None A-222 A-422

23 23542 23542 None A-223 “

A-216 – A-223 are all 3-Stage Scrubbair Systems—located directly above the plating tank(s)

A-416, A-418, A-420, A0422 are all HEPA Filter Units

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

The new permitted emission level will be 0.0015 mg/a-hr. Hence the following shows the 

permitted hex chrome emission rates before and after the permit condition modification.

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

Current 60,000,000 0.03 3.965

Post-ATCM 60,000,000 0.0015 0.198

Net Difference 0 0.0285 3.767
AN 19105/United Airline(Plant A51)

RE Frazier, P.E.

11/13/2008

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3. CEQA

Since the change of conditions will result in a decrease in the permitted emission levels, this 

application is exempt from CEQA review per Reg 2-1-312.1.

4. BEST AVAILABLE CONTROL TECHNOLOGY

Emissions are decreasing, 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, 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. It should be noted that the risks were less than 10 in a million at the 

previous emission level, 3.965 lb/yr. We would therefore expect the risk at the new control level to 

remain below 10 in a million.

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 23542 is presented in this application, as is the revised 

Condition 235432.

10. RECOMMENDATIONS

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

Condition 23542.

OLD CONDITION 23542

 COND# 23542 --------------------------------------

 The owner/operator shall comply with the following
AN 19105/United Airline(Plant A51)

RE Frazier, P.E.

11/13/2008

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 condition for Sources 16, 17, 18, 19, 20, 21, 22

 and 23 (Chrome Plate Tanks #35, 37, 38, 40, 41, 44,

 45, and 47, respectively). 

 1. The owner/operator shall not exceed a total

 combined net annual throughput of 60 million

 amp-hr in any consecutive twelve month period

 from the S-16, S-17, S-18, S-19, S-20, S-21, S-

 22 and S-23. (Basis: Toxic Risk Management) 

 2. The owner/operator shall install non-

 resettable totalizing amp-hr meters on all

 rectifiers serving the chrome plating and

 anodizing tanks. A rectifier shall not be

 operated unless its associated totalizing amp-

 hr meter is recording properly. (Basis: Toxic

 Risk Management, "Hexavalent Chromium Airborne

 Toxic Control Measure For Chrome Plating And

 Chromic Acid Anodizing Operations", Section

 93102(e)(1)) 

 3. The owner/operator shall not allow emissions

 of hexavalent chromium to exceed 0.03 mg/amp-

 hr after abatement. (Basis: ATCM Section

 93102(c)(1)(A)) 

 4. The owner/operator shall abate at all times

 during operation of S-16, S-17, S-18, S-19, S-

 20, S-21, S-22, and S-23 with A-216, A-217, A-

 218, A-219, A-220, A-221, A-222 and A-223 (Dry

 Scrubber with 3-Stage Composite Mesh Pads),

 respectively. The ventilation and abatement

 systems shall be properly maintained and kept

 in good operating condition. (Basis: TBACT) 

 5. The owner/operator shall abate at all times

 the flow from A-216 & A-217 with A-316 (HEPA

 filter), A-218 & A-219 with A-318 (HEPA

 filter), A-220 & A-221 with A-320 (HEPA

 filter), and A-222 & A-223 with A-322 (HEPA

 filter). The ventilation and abatement systems

 shall be properly maintained and kept in good

 operating condition. (Basis: TBACT) 

 6. The owner/operator shall operate all abatement

 systems within the following differential

 pressure range as established by the most

 recent District-approved performance test.

 A-216: 0.2" to 2.2"

 A-217: 0.2" to 2.2"

 A-218: 0.4" to 2.4"

 A-219: 0.3" to 2.3"

 A-220: 0.4" to 2.4"

 A-221: 0.5" to 2.5"

 A-222: 0.5" to 2.5"
AN 19105/United Airline(Plant A51)

RE Frazier, P.E.

11/13/2008

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 A-223: 0.4" to 2.4"

 A-316: 0.5" to 2.1"

 A-318: 0.6" to 2.2"

 A-320: 0.5" to 2.1"

 A-322: 0.5" to 2.1"

 (Basis: Basis: ATCM Section 93102 (e)(2) and

 Toxic Risk Management) 

 7. The owner/operator shall continuously monitor

 the pressure differential across A-216, A-217,

 A-218, A-219, A-220, A-221, A-222, A-223, A-

 316, A-318, A-320 and A-322. Each monitor

 shall be equipped with an alarm to indicate

 when the pressure differential falls outside

 of the allowed range as indicated in Part 6.

 The owner/operator shall safely shutdown

 operations of the affected source immediately

 and take corrective action when the pressure

 differential fails to meet this requirement.

 (Basis: ATCM Section 93102 (e)(2) and Toxic

 Risk Management) 

 8. In order to demonstrate compliance with Parts

 6 and 7 above, the owner/operator shall record

 the pressure drop across A-216, A-217, A-218,

 A-219, A-220, A-221, A-222, A-223, A-316, A-

 318, A-320 and A-322 at least once per week.

 The owner/operator shall record all pressure

 monitor alarms and periods the pressure

 monitors are inoperative. All parametric

 monitoring notifications as required by

 Regulation 1 shall be made to the Compliance

 and Enforcement Division. Records shall be

 kept onsite for at least 5 years from the date

 the entry was made. (Basis: Regulation 1-523,

 Toxic Risk Management and ATCM Section 93102

 (h)(4)(B)) 

 9. In order to demonstrate compliance with Part 1

 above, the owner/operator shall keep monthly

 records of the electrical current applied to

 these sources integrated over time, in units

 of amp-hrs. Monthly records shall be totaled

 every rolling 12-month period and be kept

 onsite for at least 5 years from the date the

 entry was made. (Basis: ATCM Section 93102

 (h)(4)(A) and Toxic Risk Management) 

 10. The owner/operator shall perform the

 Inspections and Maintenance requirements (e.g.

 visual inspections) pursuant to ATCM Section

 93102 (f) on A-216, A-217, A-218, A-219, A-

 220, A-221, A-222, A-223, A-316, A-318, A-320

 and A-322 at least once per quarter and

 conduct washdowns of the systems per
AN 19105/United Airline(Plant A51)

RE Frazier, P.E.

11/13/2008

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 manufacturer's recommendation. (Basis: ATCM

 Section 93102 (f) and Toxic Risk Management) 

 11. In order to demonstrate compliance with Part

 10, the owner/operator shall record the

 equipment being inspected, date, brief

 description of the working condition of the

 device during the inspections, any maintenance

 activities performed on the components of the

 air pollution control systems, and any actions

 taken to correct deficiencies found during the

 inspection. Records shall be kept onsite for

 at least 5 years from the date of entry.

 (Basis: ATCM Section 93102 (h)(1) and Toxic

 Risk Management) 

 12. In order to demonstrate compliance with the

 emission limit in Part 3, the owner/operator

 shall conduct District-approved source test on

 A-216, A-217, A-218, A-219, A-220, A-221, A-

 222, A-223, A-316, A-318, A-320 and A-322. The

 owner/operator shall perform the source test

 using the following schedule:

 a. The initial source test required by this

 part shall be conducted no later than 180

 days of initial startup.

 b. Unless Part 11(c) is satisfied, subsequent

 testing shall be performed no sooner than

 12 months and no later than 24 months from

 the date of the previous District approved

 source test demonstrating compliance.

 c. If the previous two source tests

 demonstrate compliance, the subsequent

 test shall be performed no later than 48

 months from the previous test.

 d. If a source test demonstrates non-

 compliance and the owner/operator must re-

 test to demonstrate compliance, then the

 re-test does not count as a "source test

 demonstrating compliance" as referenced in

 11(b). 

 The owner/operator shall contact the Source

 Test Section of the District at least 14 days

 in advance of each source test to obtain

 approval of the test procedures. The

 owner/operator shall notify the Source Test

 Section at least 7 days in advance of each

 scheduled source test. The owner/operator

 shall submit the source test report within 45

 days of the test date to the Source Test

 Section. A copy of all source tests results

 shall be kept on-site for at least 5 years

 from the date the record was made. (Basis:

 ATCM Section 93102(d) and Regulation 2-1-304)
AN 19105/United Airline(Plant A51)

RE Frazier, P.E.

11/13/2008

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NEW CONDITION 23542

 COND# 23542 --------------------------------------

 The owner/operator shall comply with the following

 Conditions for Sources 16, 17, 18, 19, 20, 21, 22, and 23

 (chrome plating tanks #35, 37, 38, 40, 41, 44, 45, and 47,

 respectively). Basis refers to either BAAQMD

 Regulations/Rules or California Code of Regulations, Title

 17, Section 93102 - 93102.16 and associated Appendices,

 unless otherwise noted) 

 1. Performance Standards 

 a) Emission Limits effective through 10-23-2009: 

 Emissions of hexavalent chromium shall not exceed

 0.03 mg per ampere-hour (mg/amp-hr) after abatement.

 [Basis: 93102.4(a)(1)] 

 b) Emission Limits effective 10-24-2009: 

 Emissions of hexavalent chromium shall not exceed

 0.0015 mg per ampere-hour (mg/amp-hr) after

 abatement.

 [Basis: 93102.4(b)(1)] 

 c) Throughput: The total annual combined throughput

 shall not exceed 60 million ampere-hours in any

 consecutive 12-month period. [Basis: 93102.4(b)(1)]

 d) The requirements of Parts 1a and 1b of this

 condition and the O&M Plan provision do not apply

 during periods of equipment breakdown, provided the

 provisions of the District's breakdown rules are

 met. [Basis: 93102.2(b)] 

 2. Abatement 

 a) The owner/operator shall abate at all times during

 operation of S-16, S-17, S-18, S-19, S-20, S-21,

 S-22, and S-23 with A-216, A-217, A-218, A-219,

 S-220, A-221, A-222, and A-223 (Dry Scrubber with

 3-stage Composite Mesh Pads), respectively.

 [Basis: TBACT] 

 b) The owner/operator shall abate at all times the flow

 from A-216 & A-217 with A-316 HEPA filter, A-218 &

 A-219 with A-318 HEPA filter, A-220 & A-221 with

 A-320 HEPA filter, and A-222 & A-223 with A-322 HEPA

 filter. [Basis: TBACT] 

 The ventilation and abatement systems shall be
AN 19105/United Airline(Plant A51)

RE Frazier, P.E.

11/13/2008

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 properly maintained and kept in good working

 condition. 

 3. Source Testing 

 a) The owner/operator shall perform a source test by

 October 24, 2009 to demonstrate compliance with the

 emission performance standard specified in Part 1b.

 An existing District-approved source test may be

 used to demonstrate compliance with this Part, as

 long as the existing source test was conducted in

 accordance with ATCM Section 93102.7(b) and (c).

 [Basis: 93102.7(a)(1)(A)] 

 b) The owner/operator shall perform source tests to

 demonstrate compliance according to the following

 schedule: 

 i. Unless Part 3.b)ii. is satisfied, subsequent

 source testing shall be performed no later

than 36 months after the date of the previous

 District-approved source test demonstrating

 compliance.

 ii. If the previous two consecutive source tests

 demonstrate compliance, the subsequent tests

shall be performed no later than 48 months

after the previous source test.

 iii. If a source test demonstrates non-compliance,

 then the owner/operator must perform another

source test to demonstrate compliance.

Subsequent source tests to demonstrate

compliance shall be performed no later than

24 months after the previous source test. If

after two consecutive source tests at the 24

month frequency, both of which demonstrate

compliance, the source test frequency reverts

to the original schedule in Part 3.b)i. 

 c) Non-compliant source test: After conducting a

 source test which demonstrates non-compliance the

 owner/operator shall review and adjust or repair the

 plating operation and associated emission control

 system. A source test to demonstrate compliance

 shall be performed no later than 30 days after the

 chrome plating system adjustments/repairs are

 completed. 

 d) Any chrome plating bath that is non-operational at

 the time a source test is due does not have to be

 tested at that time. Upon subsequent start-up of

 any such bath, a source test shall be conducted

 within 30 days. 

 e) Source Testing Protocol: A written source test
AN 19105/United Airline(Plant A51)

RE Frazier, P.E.

11/13/2008

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 protocol based on 93102.7(c) shall be provided for

 District approval prior to conducting any source

 test for compliance. This source testing protocol

 shall include testing methods, length of sample

 period, plating facilities to be operated during the

 source test, sampling equipment and methods, as well

 as the planned date for the source test. 

 f) The owner/operator shall contact the District Source

 Test Section at least 14 days in advance of the

 source test or as directed by the ATCM to obtain

 approval of the test protocol. The owner/operator

 shall notify the District Source Test Section at

 least 7 days in advance of each scheduled source

 test. [Basis: 93102.7] 

 4. 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 for chrome

 plating and anodizing. [Basis: 93102.5(b)] 

 5. 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
AN 19105/United Airline(Plant A51)

RE Frazier, P.E.

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 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. 

 6. 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: 93102.10(a),

 93102.12(c)(1)] 

 b) Dry Scrubber Pressure Drop: The owner/operator

 shall continuously monitor the pressure drop across

 A-216, A-217, A-218, A-219, A-220, A-221, A-222, and

 A-223 dry scrubbers with 3-stage composite mesh pad

 units. The pressure drop shall be maintained within

 plus or minus 2 inches of water of the value

 established during the most recent source test to

 demonstrate compliance with the emission limitations

 of Part 1. Pressure drop readings shall be recorded

 at a frequency of at least one time per operating

 week. [Basis: 93102.9(b), 93102.12(c)(2)] 

 c) HEPA Filter Pressure Drop: The owner/operator shall

 continuously monitor the pressure drop across A-316,

 A-318, A-320, and A-322 HEPA filters. The pressure

 drop shall be maintained within minus 1⁄2 times to +2

 times the inches of water of the value established

 during the most recent source test to demonstrate

 compliance. Pressure drop readings shall be

 recorded at a frequency of at least one time per

 operating week. [Basis: 93102.9(b),

 93102.12(c)(2)] 

 7. 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
AN 19105/United Airline(Plant A51)

RE Frazier, P.E.

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 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

 air pollution control equipment and amp-hr

 meters/totalizers.

 [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] 

 8. Inspection & Maintenance Frequency 

 a) The owner/operator shall perform visual inspections

 of the abatement systems and associated ductwork

 pursuant to ATCM Section 93102.10(a) at least once

 per calendar quarter and conduct wash downs of the

 CMP per manufacturer's recommendation. [Basis:

 93102.10(a) and Reg 2-5] 

 b) In order to demonstrate compliance with Part 8a,

 the owner/operator shall record the equipment being

 inspected, date, brief description of the working

 condition of the device during the inspections, any

 maintenance activities performed on the components

 of the air pollution control systems, and any

 actions taken to correct deficiencies found during

 the inspection. 

 9. 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 

 i. record monthly and cumulative 12-month

 rectifier ampere-hour totals and

 ii. record the pressure drop across the

 abatement device(s) at least once a week. 
AN 19105/United Airline(Plant A51)

RE Frazier, P.E.

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 c) Breakdown Records noting the occurrence,

 duration, cause (if known), and action taken. 

 d) Records of excesses of the emission limitations

 set forth in Part 1 or the monitoring parameters

 established under Part 6 noting any exceedances of

 the ampere-hour throughput or pressure drop limits.

 e) Housekeeping Records demonstrating compliance

 with Part 3, above, including date and time of

 housekeeping activity. 

 10. Reporting 

 a) Source Test Reports: The owner/operator shall

 report source test results used to demonstrate

 compliance to the District Source Test Section no

 later than 60 days after the test date. The content

 of the source test reports shall contain the

 information identified in Appendix 1 of the

 applicable ATCM. Source test records shall be

 maintained onsite at the facility and made available

 to the District upon request, for a period of 5

 years from the date of the source test. [Basis:

 93102.13(a)] 

 b) Annual Compliance Status Report: The owner/operator

 shall submit an annual compliance status report to

 the District on or before February 1, and shall

 include the following information for the preceding

 calendar year. 

 The content of the ongoing status shall include the

 information identified in Appendix 3 of the

 applicable ACTM. The report shall contain the name,

 title and signature of the responsible official who

 is certifying the accuracy of the report. [Basis:

 93102.13(c)]