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 A cid 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

in volved 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 Ab atement

- 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

crite ria, 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 la w 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 p ermitted. 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 3.767AN 19105/United Airline (Plant A51 )

RE Frazier, P.E.

11/13/2008

2 3. CEQA

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

application is exempt from CEQA r eview 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 f rom 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 sha ll comply with the followingAN 19105/United Airline (Plant A51 )

RE Frazier, P.E.

11/13/2008

3 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 tot al

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/op erator 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/oper ator 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

- 2 17 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 ma intained 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" t o 2.5"AN 19105/United Airline (Plant A51 )

RE Frazier, P.E.

11/13/2008

4 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 ow ner/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 En forcement 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. Month ly 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 perAN 19105/United Airline (Plant A51 )

RE Frazier, P.E.

11/13/2008

5 manufacturer's recommendation. (Basis: ATCM

Section 93102 (f) and Toxic Risk Management)

11. In order to demonstrate compl iance 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 t he 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: AT CM 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 t est 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 b y 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 mo nths 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 la ter 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 "s ource 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 adv ance 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 subm it 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

6 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 otherwis e 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 duri ng

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 beAN 19105/United Airline (Plant A51 )

RE Frazier, P.E.

11/13/2008

7 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

s chedule:

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 n o 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 com pliance.

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 conduct ing 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 complian ce

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 testAN 19105/United Airline (Plant A51 )

RE Frazier, P.E.

11/13/2008

8 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. Ho usekeeping

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 contai ner.

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 leastAN 19105/United Airline (Plant A51 )

RE Frazier, P.E.

11/13/2008

9 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. Mo nitoring

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 Pressu re 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 in ches 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. [Bas is: 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 plati ng operation,

which shall be retained onsite and made available for

inspection upon request. Any revisions to the O & MAN 19105/United Airline (Plant A51 )

RE Frazier, P.E.

11/13/2008

10 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 inspection s

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 d eficiencies found during

the inspection.

9. Recordkeeping

The owner/operator shall maintain the following records

for at least five year s, 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 corre ctive 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.

11/13/2008

11 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

w ith Part 3, above, including date and time of

housekeeping activity.

10. Reporting

a) Source Test Reports: The owner/operator shall

repor t 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 id entified 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 i n 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)]