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 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

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 ac cordance 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 i n

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

em issions 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. Hen ce 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 Differenc e 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.AN 19109/WRE

- Colortech (Plan t A4538)

RE Frazier, P.E.

11/13/2008

2 4. BEST AVAILABLE CONTROL TECHNOLOGY

Emissions are decreasing, therefo re 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, theref ore 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

pre vious 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

fro m chrome plating tank S

- 1 shall

not exceed 6 million ampere

- hours

in any consecutive twelve

- month

period.AN 19109/WRE

- Colortech (Plan t A4538)

RE Frazier, P.E.

11/13/2008

3 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 exha usted 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 Li mits

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

- h r, 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 a bove

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

th e requirement for ongoing compliance

source testing in lieu of process

parameter monitoring.

5. Parameter MonitoringAN 19109/WRE

- Colortech (Plan t A4538)

RE Frazier, P.E.

11/13/2008

4 a) To demonstrate compliance wi th

Condition 1, above, WRE/ColorTech

shall install, operate and maintain

a continuous recording, non

- resettable ampere

- hour meter that

operates on the electrical power

lin es 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 acidAN 19109/WRE

- Colortech (Plan t A4538)

RE Frazier, P.E.

11/13/2008

5 buildup on the pads, and no

evidence of chemical attack that

would affect the st ructural

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

t o 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 quart er 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 s hall be

installed and maintained as per

manufacturer's recommendations.

7. Operation and Maintenance Plan

a) WRE/ColorTech shall prepare an

operation a nd 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 monito ring

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 forAN 19109/WRE

- Colortech (Plan t A4538)

RE Frazier, P.E.

11/13/2008

6 District in spection 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 t ime 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 t o demonstrate that the

inspection and maintenance

requirements of Condition 6,

above, have been satisfied.

c) Performance test records:

WRE/ColorTech shall maintain test

repo rts documenting the conditionsAN 19109/WRE

- Colortech (Plan t A4538)

RE Frazier, P.E.

11/13/2008

7 and results of all performance

tests.

d) Monitoring data records:

WRE/ColorTech shall maintain

records of monitoring data as

required by Conditi ons 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 durat ion,

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, SectionAN 19109/WRE

- Colortech (Plan t A4538)

RE Frazier, P.E.

11/13/2008

8 93102

- 93102.16 an d associated appendices, unless

otherwise noted.

1. Performance Standards

a) Emission Limits effective through 10

- 23

- 2009:

Emissions of hex avalent 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 hex avalent 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 a t 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

main tained 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

emissi on 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 A TCM Section 93102.7(b) & (c).

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

b) The owner/operator shall perform source tests toAN 19109/WRE

- Colortech (Plan t A4538)

RE Frazier, P.E.

11/13/2008

9 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 t est 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 pe rformed 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 sou rce 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 Pr otocol: 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 Dr op: record pressure drop at

least one time every 15 minutes of operation.

ii. A

- 3 Pressure Drop: record pressure drop atAN 19109/WRE

- Colortech (Plan t A4538)

RE Frazier, P.E.

11/13/2008

10 least one time every 15 minutes of operation.

f) The owner/operator shal l 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, 200 9, 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 sto red 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 chr ome 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 t hat 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 aAN 19109/WRE

- Colortech (Plan t A4538)

RE Frazier, P.E.

11/13/2008

11 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 rece nt 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), 910 2.12(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,

whi ch 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/tota lizers. [Basis: 93102.11]

b) A checklist to document the inspection, operationAN 19109/WRE

- Colortech (Plan t A4538)

RE Frazier, P.E.

11/13/2008

12 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

pursuan t 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 orde r 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

maintena nce activities performed on the components

of the air pollution control systems, and any

actions taken to correct deficiencies found during

the inspection.

9. Recordkeepin g

The owner/operator shall maintain the following records

for at least five years, with the most recent two years

maintained onsite.

a) I nspection 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 th e 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, abov e, including date and time ofAN 19109/WRE

- Colortech (Plan t A4538)

RE Frazier, P.E.

11/13/2008

13 housekeeping activity.

10. Reporting

a) Source Test Reports: The owner/operator shall

report source test re sults 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 Appe ndix 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)]