ENGINEERING EVALUATION REPORT

PLANT NAME WRE-Colortech

APPLICATION NUMBER 19109

PLANT NUMBER 4538

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

1 16358 16358 None A-2 CMP A-3 HEPA

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 6,000,000 0.006 0.0793

Post-ATCM 6,000,000 0.0015 0.0198

Net Difference 0 0.0045 0.059

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.
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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, 0.0793 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 16358 is presented in this application, as is the revised 

Condition 16358.

10. RECOMMENDATIONS

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

Condition 16358.

OLD CONDITION 16358

 COND# 16358 --------------------------------------

 1. Annual Usage 

 The total annual (net) throughput

 from chrome plating tank S-1 shall

 not exceed 6 million ampere-hours

 in any consecutive twelve-month

 period. 
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 2. Abatement 

 This source shall not be operated

 unless all chrome plating tank

 emissions are vented through A2 Duall

 Composite Mesh Pad (CMP) System and A3

 HEPA Filtration System. All emissions

 shall be exhausted from P1 at a height

 of at least 43 feet (13 meters) above

 grade. The abatement system shall be

 well maintained and kept in good

 operating condition. 

 3. Emission Limits 

 Emissions of hexavalent chromium shall

 not exceed 0.005 milligram per ampere-

 hour (mg/a-hr) after abatement. 

 4. Source Test 

 Initial Compliance Source Test: To

 demonstrate compliance with condition

 3 above, WRE/ColorTech must perform a

 District-approved source test

 (according to a District approved

 protocol) on the exhaust stack within

 60 days of startup. 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. 

 Ongoing Compliance Source Testing:

 To demonstrate ongoing compliance

 with Condition 3, above, WRE/ColorTech

 shall perform a District approved

 source test according to the above

 specifications, at a frequency not to

 exceed 24 months. If after 2 such

 ongoing compliance source tests, no

 exceedances are noted, WRE/ColorTech

 may petition the District to rescind

 the requirement for ongoing compliance

 source testing in lieu of process

 parameter monitoring. 

 5. Parameter Monitoring 
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 a) To demonstrate compliance with

 Condition 1, above, WRE/ColorTech

 shall install, operate and maintain

 a continuous recording, non-

 resettable ampere-hour meter that

 operates on the electrical power

 lines connected to the tank rectifier.

 A separate meter shall be hard-wired

 for each rectifier if applicable. 

 b) WRE/ColorTech shall continuously

 monitor the pressure drop across

 A2 composite mesh pad scrubber.

 The gauge shall be located so that

 it can be easily visible and in

 clear sight of the operation or

 maintenance personnel. The

 pressure drop shall be maintained

 within plus or minus 1 inch of water of

 the value established during the

 performance test to demonstrate

 compliance with the emission

 limitation. 

 c) WRE/ColorTech shall continuously

 monitor the pressure drop across

 A3 HEPA Filtration Unit. The gauge

 shall be located so that it can be

 easily visible and in clear sight

 of the operation or maintenance

 personnel. The pressure drop

 across the HEPA Filtration Unit

 shall be maintained between 0.275

 and 1.10 inches W.G. (based on the

 source test of 09/13/2001). Upon

 reaching 1.10 inches W.G. WRE/ColorTech

 shall replace the existing HEPA

 prefilter with a new HEPA prefilter.

 If the pressure drop across the HEPA

 Filtration Unit is still greater than

 1.10 inches of water, WRE/ColorTech

 shall replace the HEPA filter

 component.

 (Basis: Reg 11 Rule 8 (e)(2)) 

 6. Inspection/Maintenance 

 a) WRE/ColorTech shall perform visual

 inspections of the composite mesh

 pad scrubber A2 and A3 HEPA

 Filtration Unit 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
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 buildup on the pads, and no

 evidence of chemical attack that

 would affect the structural

 integrity of the devices.

 b) WRE/ColorTech shall visually inspect

 the back portion of the mesh pad

 closest the stack at a frequency

 of at least one time per quarter

 to ensure there is no breakthrough

 of chromic acid mist.

 c) WRE/ColorTech shall visual 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.

 d) WRE/ColorTech shall perform

 washdowns of the composite mesh

 pads at a frequency as recommended

 by the manufacturer.

 e) The ampere-hour meter shall be

 installed and maintained as per

 manufacturer's recommendations. 

 7. Operation and Maintenance Plan 

 a) WRE/ColorTech shall prepare an

 operation and maintenance (O & M)

 plan. The plan shall incorporate

 the inspection and maintenance

 requirements as noted in Condition

 6, above, and shall include the

 following elements:

 1) a standardized checklist to

 document the operation and

 maintenance of the source, the

 add-on air pollution control

 devices, and the process and

 control system monitoring

 equipment, and

 2) procedures to be followed to

 ensure that equipment is

 properly maintained.

 b) O & M plan retention:

 WRE/ColorTech shall keep the

 Written operation and maintenance

 plan on record after it is

 developed to be made 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,

 WRE/ColorTech shall keep previous

 versions of the O & M Plan on

 record to be made available for
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 District inspection upon request,

 for a period of 5 year 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,

 WRE/ColorTech 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 WRE/ColorTech for

 at least five years total; and at

 least two years on site. 

 a) Inspection records for A2

 composite mesh pad scrubber and

 A3 HEPA Filtration Unit:

 WRE/ColorTech shall maintain

 inspection records to document

 that the Inspection/Maintenance

 requirements and the O & M Plan as

 required by Conditions 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 (i.e. ductwork,

 filter pad, fan, etc), and 5) any

 action taken to correct

 deficiencies found during

 inspection.

 b) WRE/ColorTech shall maintain

 records to demonstrate that the

 inspection and maintenance

 requirements of Condition 6,

 above, have been satisfied.

 c) Performance test records:

 WRE/ColorTech shall maintain test

 reports documenting the conditions
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 and results of all performance

 tests.

 d) Monitoring data records:

 WRE/ColorTech shall maintain

 records of monitoring data as

 required by Conditions 1 and 5,

 as follows:

 e) Breakdown records: WRE/ColorTech

 shall maintain records of the

 occurrence, duration, and cause

 (if known) and action taken on

 each breakdown.

 f) Records of excesses:

 WRE/ColorTech shall maintain

 records of exceedances of:

 1) the emission limitation

 identified in Condition 3;

 2) the monitoring parameter values

 of Condition 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. 

 9. Reporting 

 a) On an annual basis, WRE/ColorTech

 shall prepare a summary report to

 the District to document the

 ongoing compliance status. This

 report shall be made available to

 the District upon request.

 b) Breakdown reports: WRE/ColorTech

 shall report breakdowns as required

 by the District breakdown procedures

 identified in Regulation 1.

NEW CONDITION 16358

 COND# 16358 --------------------------------------

 The owner/operator shall comply with the following

 Conditions for Source 1 Chrome Plating Tank.

 Basis refers to either BAAQMD Regulations/Rules or

 California Code of Regulations, Title 17, Section
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 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

 0.006 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 throughput at S-1

 plating tank shall not exceed 6 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 provisions 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-1 with plating tank emissions vented

 through A-2 Composite Mesh Pad (Spectra U-1000) unit. 

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

 from A-2 with A-3 HEPA Filter unit, with emissions

 exhausted from P-1 at a height of at least 43 feet

 (13 meters) above grade.

 [Basis: 93102.4(b)(1), Reg 2-5] 

 The ventilation and abatement system shall be properly

 maintained and kept in good working condition. 

 3. Source Test 

 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) & (c).

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

 b) The owner/operator shall perform source tests to
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 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

 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. 

 For the purpose of maintaining ongoing compliance,

 the following parameters shall be monitored and

 recorded at the listed frequency during the source

 testing period: 

 i. A-2 Pressure Drop: record pressure drop at

 least one time every 15 minutes of operation.

 ii. A-3 Pressure Drop: record pressure drop at
AN 19109/WRE-Colortech (Plant A4538)

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 least one time every 15 minutes of operation. 

 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

 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
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 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) A-2 Pressure Drop: The owner/operator shall

 continuously monitor the pressure drop across A-2

 Spectra U-1000 CMP unit. 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), 9102.12(c)(2)]

 c) A-3 Pressure Drop: The owner/operator shall

 continuously monitor the pressure drop across A-3

 HEPA filter. 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

 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
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 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 maintenance of the

 A-2 Spectra U-1000 CMP unit per manufacturer

 recommendations. [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:

 [Basis: 93102.12] 

 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 per

 operating week. 

 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
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 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)]