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 

below 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

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 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)

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11/13/2008

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3. CEQA

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

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

4. BEST AVAILABLE CONTROL TECHNOLOGY

Emissions are decreasing, therefore BACT is not applicable.

5. EXEMPTIONS

There are no applicable exemptions.

6. OFFSETS

Offsets are not applicable, since emissions decrease, therefore no offset triggers are exceeded.

7. TOXIC EVALUATION

Permitted emission levels decrease, therefore no toxic evaluation is required. Previous toxic risk 

evaluations have been conducted showing there are no significant risks to any member of the 

public from these operations. It should be noted that the risks were less than 10 in a million at the 

previous emission level, 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 toxic 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 revised 

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

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 plating tank S-1 shall 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 with 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

 condition. 

 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 District 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 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. 

 The results from the approved source test of

 December 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 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) 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

 maintenance 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. 
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 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

 tension 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 operating 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 per 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 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) 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

 incorporate 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 pollution control device, and the

 process and control system monitoring

 equipment, and b) procedures to be followed to

 ensure that equipment is properly maintained.
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RE Frazier, P.E.

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 b) O & M plan retention: Teikuro 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, 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 breakdowns: 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 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 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 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) Teikuro shall maintain records to demonstrate

 that the inspection 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) Monitoring 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)

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 (if known) and action 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) Records 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

 rectifier 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 reports: 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 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

 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)

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 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 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 owner/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 with a stalagmometer, or 35 dynes/centimeter

 if measured with a tensiometer.

 [Basis: 93102.9(d)(2)] 

 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: 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)

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 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. Bath surface tension: one time, before tank

 operation commences.

 ii. A-1 Pressure Drop: record pressure drop at

 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
AN 19106/Teikuro (Plant A1794)

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 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/operator 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 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 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 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

 physical barrier, which may include, but is not
AN 19106/Teikuro (Plant A1794)

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 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-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 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) Surface Tension Monitoring: In order to demonstrate

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

 tension 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 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] 
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 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 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 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)

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 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

 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)]