ENGINEERING EVALUATION REPORT

PLANT NAME Teikuro America

APPLICATION NUMBER 19106

PLANT NUMBER 1794

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 8012 8012 HCA 6.2 A

- 1 Duall n/a

Teikuro is not required to operate with a bath additive. But since they use HCA 6.2 for hygiene

around the bath, they are required to maintain enough chemical to keep the surface tension at or

be low 45 dyne/cm (stalagmometer measured)

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

Secti on 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 S ection 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

- l evel 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 sh ows 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 3 ,000,000 0.03 0.198

Post

- ATCM 3 ,000,000 0.0015 0.00991

Net Difference 0 0.0285 0.1883**AN 19106/Teikuro (Plant A1794)**

**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 review per Reg 2

- 1

- 312.1.

4. BEST AVAILABLE CONTROL TECHNOLOGY

Emissions are decreasing, therefore BACT is not appl icable.

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 evalua tion 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 leve l, 0.198 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 to xic control measure.

9. CONDITIONS

The previous version of Condition 8012 is presented in this application, as is the revised Condition

8012

.

10. RECOMMENDATIONS

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

Condition 8012

.

OLD CONDITION 8012

COND# 8012

--------------------------------------

1. Annual Usage

The total annual (net) throughput from chrome**AN 19106/Teikuro (Plant A1794)**

**RE Frazier, P.E.**

**11/13/2008**

3 plating tank S

- 1 sh all not exceed 3 million ampere

- hours in any consecutive twelve

- month period.

2. Abatement

This source shall not be operated unless the plating

bath is maintained w ith a wetting agent bath additive

(at an appropriate surface tension level) and

emissions are vented through A1 Duall Composite

Mesh Pad (CMP) System. The abatement system

shall be well maintained and kept in good operating

condit ion.

3. Emission Limits

Emissions of hexavalent chromium shall not exceed

0.03 milligram per ampere

- hour (mg/a

- hr) after

abatement.

4. Source Test

To demonstrate compliance with condition 3 above,

Teikuro must perform a District

- approved source test

(according to a Di strict approved protocol) on the

exhaust stack. 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 compl ete

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.

The results from the approved source test of

Decem ber 11, 1996 may be used to demonstrate

compliance with Condition 3, above.

5. Parameter Monitoring

a) To demonstrate compliance with Condition 1,

above, Teikuro shall i nstall, 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 applica ble.

b) Teikuro shall continuously monitor the pressure

drop across A

- 1 composite mesh pad. The

gauge shall be located so that it can be easily

visible and in clear sight of the operation or

mainten ance personnel. The pressure drop shall

be maintained within + 1 inch of water of the

value established during the performance test to

demonstrate compliance with the emission

limitation.**AN 19106/Teikuro (Plant A1794)**

**RE Frazier, P.E.**

**11/13/2008**

4 c) Teikuro shall monitor the surface tension of the

chrome plating tank with either a

stalagmometer or tensiometer using U.S. EPA

Method 306B. The surface tension shall be

maintained at or below 45 dyne/cm. Surface

te nsion shall be measured daily for 20 operating

days and weekly thereafter as long as there is

no violation of the surface tension

requirements. If a violation occurs, the

measurement frequency shall return to daily for

20 operatin g days and weekly thereafter.

6. Inspection/Maintenance

a) Teikuro shall perform visual inspections of the

composite mesh pad scrubber A

- 1 at a

frequency of at least one time p er calendar

quarter. This visual inspection is to ensure

that there is proper drainage, no unusual

chromic acid buildup on the pads, and no

evidence of chemical attack that would affect

the structural integrity of the device.

b) Teikuro shall visually inspect the back portion

of the mesh pad closest the fan at a frequency

of at least one time per quarter to ensure there

is no breakthrough of chromic acid mist.

c) Teikuro shall visual inspect ductw ork from

tank to the control device at a frequency of at

least one time per calendar quarter to ensure

there are no leaks.

d) Teikuro 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.

f) The stalagmometer or tensiometer used to

measure plating bath surface tension shall be

calibrated and maintained as per

manufacturer's specifications.

7. Operation and Maintenance Plan

a) Teikuro shall prepare an operation and

maintenance (O & M) plan. The plan shall

i ncorporate the inspection and maintenance

requirements as noted in Condition 6, above,

and shall include the following elements: a) a

standardized checklist to document the

operation ad maintenance of the source, the

add

- on air pol lution control device, and the

process and control system monitoring

equipment, and b) procedures to be followed to

ensure that equipment is properly maintained.**AN 19106/Teikuro (Plant A1794)**

**RE Frazier, P.E.**

**11/13/2008**

5 b) O & M plan retention: Teikuro shall keep the

written operati on 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, Teikuro

shall keep previous versions of the O & M

Plan on record to be made available for

District inspection upon request, for a period

of 5 year after each revision to the plan.

d) Revisions to address breakdow ns: The O & M

Plan shall be revised as necessary to minimize

breakdowns.

To satisfy the inspection and maintenance

procedures, Teikuro may use applicable standard

operating procedur e (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 Teikuro for at least five years total; and at least

two years on site.

a) Inspection records for A

- 1 composite mesh pad

scrubber: Teikuro 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 th e 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) Teikuro shall maintain records to demonstrate

that the inspectio n and maintenance

requirements of Condition 6, above, have been

satisfied.

c) Performance test records: Teikuro shall

maintain test reports documenting the

conditions and results of all performance tests.

d) Monitor ing data records: Teikuro shall

maintain records of monitoring data as

required by Conditions 1 and 5, as follows:

e) Breakdown records: Teikuro shall maintain

records of the occurrence, duration, and cause**AN 19106/Teikuro (Plant A1794)**

**RE Frazier, P.E.**

**11/13/2008**

6 (if known) and ac tion taken on each

breakdown.

f) Records of excesses: Teikuro shall maintain

records of exceedances of: a) the emission

limitation identified in Condition 3; b) 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.

g) Re cords demonstrating facility size: Teikuro

shall keep records demonstrating small facility

size by demonstrating that emissions of hex

chrome are less than 2 pounds/year (12 month

basis) or by actual rolling 12

- month cumulative

re ctifier capacity (less than 60 million ampere

- hour/yr) or by records demonstrating

compliance with Condition 1, above.

h) Records of wetting agent chemical additions:

Teikuro shall maintain records of wetting agent

additions to plating bath S

- 1 including the

following 1) date, 2) time, 3) approximately

quantity added, 4) product identification of the

fume suppressants added to the bath.

9. Reporting

a) On an annual basis, Teikuro 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 report s: Teikuro shall report

breakdowns as required by the District

breakdown procedures identified in Regulation

1.

NEW CONDITION 8012

COND# 8012

--------------------------------------

The owner/operator shall comply w ith the following

Conditions for Source 1 Chrome Plating Tank.

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**AN 19106/Teikuro (Plant A1794)**

**RE Frazier, P.E.**

**11/13/2008**

7 0.03 mg p er 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 shall not

exceed 3 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

- 1 Duall Composite Mesh Pad (CMP) system.

[Basis: 93102.4(b)]

The ventilation and abatement system shall be properly

maintained and kept in good working condition.

b) The owne r/operator uses Hunter chemical HCA 6.2 fume

suppressant bath additive to assist in housekeeping

efforts around the plating tank. The plating bath

surface tension shall not exceed 45 dynes/centimeter

if measured wit h a stalagmometer, or 35 dynes/centimeter

if measured with a tensiometer.

[Basis: 93102.9(d)(2)]

3. Source Test

a) The owner/operator shall perfo rm 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 thi s part, as long as

the existing source test was conducted in

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

[Basis: H&S Code 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**AN 19106/Teikuro (Plant A1794)**

**RE Frazier, P.E.**

**11/13/2008**

8 District

- approved source test demonstrating

compliance.

ii. If the previous two consecutive source tests

demonstrate co mpliance, 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 sour ce 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 P art 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 emis sion 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 conducte d

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. Bath surface tension: one time, before tank

operation commences.

ii. A

- 1 Pressure Drop: record pressure drop at

least one t ime 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 t est protocol. The owner/operator**AN 19106/Teikuro (Plant A1794)**

**RE Frazier, P.E.**

**11/13/2008**

9 shall notify the District Source Test Section at

least 7 days in advance of each scheduled source

test. [Basis: 93102.7]

g) If the owner/operat or chooses to switch to a

different bath additive, the plating tank must

be re

- source tested within 30 days to demonstrate

compliance with the applicable Part 1 limit(s).

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 com pliance/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: 931 02.5(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 con tainer.

c) Any liquid or solid 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 ch rome

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 leas t

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**AN 19106/Teikuro (Plant A1794)**

**RE Frazier, P.E.**

**11/13/2008**

10 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

amp ere

- 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

- 1 Pressure Drop: The owner/operator shall

continuously monitor the pressure drop across A

- 1

Duall Composite Mesh Pad sytem . The pressure drop

shall be maintained within plus or minus 2 i nches 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) Surface Tension Monitoring: In order to demonstrate

compliance with Part 2.b), above, the surface

ten sion shall be initially measured and recorded

daily for 20 operating days. If there is no

exceedance of the surface tension limit during the

initial 20 operating day tests, the measurement

frequency may be automatically extended to one time

per calendar week of operation. If an exceedance

occurs, the measurement frequency shall return to

daily for 20 operating days, and weekly thereafter.

[Basis: 93102. 12(c)(4)(B)]

7. Operation & Maintenance (O&M) Plan

The owner/operator shall prepare an operation and

maintenance plan for the chrome plating operation,

which shall be retain ed 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 pl an. 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: 9 3102.11]**AN 19106/Teikuro (Plant A1794)**

**RE Frazier, P.E.**

**11/13/2008**

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. This visual inspection is to

ensure that there is proper drainage, no unusual

chromic acid buildup, and no evidence of chemical

attack that would affect the structural integrity

of the devices. [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 de scription 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 def iciencies 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 correcti ve actions.

b) The owner/operator shall:

[Basis: 93102.12]

i. Record the plating bath surface tension

according to the testing frequencies noted

in Part 6.c), and

ii. Record monthly and cumulative 12

- month

rectifier ampere

- hour totals.

iii. Record A

- 1 Duall CMP pressure drop

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 or ampere

- hour**AN 19106/Teikuro (Plant A1794)**

**RE Frazier, P.E.**

**11/13/2008**

12 limits of Part 1, the surface tension

limits of Part 2, or the pressure drop limits

established under Part 6.b).

e) Housekeeping Records demonstrating compliance

with Part 5, above, including date and time of

housekeepin g activity.

10. Reporting

a) Source Test Reports: The owner/operator shall

report source test results used to demonstrate

compliance to t he 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 te st 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 th e name,

title and signature of the responsible official who

is certifying the accuracy of the report.

[Basis: 93102.13(c)]