ENGINEERING EVALUATION REPORT

PLANT NAME Babbitt Bearing Co, Inc.

APPLICATION NUMBER 19106

PLANT NUMBER 4019

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 t he 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 Ba th Control Abatement

- 1 Abatement

- 2

1 6471 6471 Bayowet FT

248 A

- 2 A

- 1

Wet Scrubber

2 “ “ “ A

- 3 “

3 “ “ “ A

- 4 “

A

- 2, A

- 3, A

- 4 = mist eliminators, located at bath. BBC is not required to operate with a bath

additive. But since they use Bayowet FT

- 248 f or 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, enu merated 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 Dis trict

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.**AN 19107/BBC (Plant A4019)**

**RE Frazier, P.E.**

**11/13/2008**

2 Basis Throughput, a

- hr/yr Factor, mg/a

- hr Emissio ns, lb/yr

Current 44 ,000,000 0.006 0. 58

Post

- ATCM 44 ,000,000 0.0015 0.15

Net Difference 0 0.045 0. 44

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 R eg 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 t riggers 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 o perations. It should be noted that the risks were less than 10 in a million at the

previous emission level, 0.58 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 purpos e 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 6471 is presented in this application, as is the revised Condition

6471

.

10. RECOMMENDATIONS

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

Condition 6471

.

OLD CONDITION 6471**AN 19107/BBC (Plant A4019)**

**RE Frazier, P.E.**

**11/13/2008**

3 COND# 6471

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

1) Throughput

The total annual combined throughput at sources S

- 1, S

- 2, and S

- 3 shall not exceed 44 million ampere

- hours in

any consecutive twelve month period.

2) Abatement

These sources shall not be operated unless a wetting

agent additive is employed with bath surface tension

not to exceed 45 dyne/cm and emissions vented through

A

- 2 mist eliminato r and A

- 1 wet scrubber.

3) Emission Limits

Emissions of hexavalent chromium shall not exceed 0.006

mg/amp

- hr after abatement.

4) Surface Te nsion Monitoring

- Frequency

To demonstrate compliance with Condition 2, above, the

surface tension of sources S

- 1, S

- 2, and S

- 3 shall be

monitored at a frequency of at least one time every 4

ho urs of source operation.

If after 40 hours of source operation, the surface

tension monitoring results indicate no exceedances of

the maximum surface tension standard identified in

Condition 2, above, the monitoring frequency can be

reduced to at least one time every 8 hours of source

operation.

If further surface tension monitoring results indic ate

no exceedances of the maximum surface tension standard

identified in Condition 2, above, after an additional

40 hours of operation, the monitoring frequency can be

further reduced to at least one time every 40 hours of

source operation.

5) Surface Tension Monitoring

- Testing Methods

Surface tension testing shall be conducted as specified

in EPA Method 306

- B by the use of a stalagmometer or

Preciser Tensiometer as directed by manufacturers

instructions. Alternate test methods may also be used

if the method has been appropriately validated using

EPA Method 301, Appendix A, 40 CFR Part 63.

6) Source Testing

Biennial Source Testing: Babbitt Bearing shall perform

a District approved source test of the chrome plating**AN 19107/BBC (Plant A4019)**

**RE Frazier, P.E.**

**11/13/2008**

4 system (after abate ment) at a frequency of at least

once in any 24 calendar month period. These source

tests shall determine the mass emissions of both total

and hexavalent chromium in g/hr, and mg/amp

- hr, and

mg/dscm for each abatement line as emitted after

abatement. A complete report shall be submitted to the

District's Source Test Manager and this source test

shall demonstrate compliance with Condition 3, above.

Sour ce Testing Protocol: A written source test

protocol shall be submitted for District approval prior

to conducting any source test for compliance. This

source test protocol shall include testing methods,

length of sample period, sampling equipment and

methods, as well as the planned date for the source

test.

7) Recordkeeping

Throughput Records: To demonstrate compliance with

Condition 1, above, monthly records of current applied

to this these sources integrated over time, in units of

amp

- hrs, shall be kept (onsite) and maintain ed. Such

records shall be submitted to the BAAQMD on an annual

basis via the annual update program.

Surface Tension Measurement Records: To demonstrate

compliance with Conditions 2, 4, and 5, above, records

of all surface tension tests shall be kept (onsite) and

maintained. Such records shall include date and time

of testing, raw data sheets appropriate to the surface

tension testing procedur e, documentation of

calculations, and surfactant chemical addition

quantities.

Retention of Records: All records shall be kept and

maintained for a perio d of at least 5 years.

NEW CONDITION 6471

COND# 6471

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

The owner/operator shall comply with the following

Conditions for Sources 1, 2, and 3 Chrome Plating Tanks.

Basis refers to either BAAQMD Re gulations/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 19107/BBC (Plant A4019)**

**RE Frazier, P.E.**

**11/13/2008**

5 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 shall not

exceed 44 million ampere

- hours in any consecutive

12

- month period. [Basis: 93102.4(b)(1)]

d) The requirements of Parts 1a and 1b of this conditio n

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, S

- 2, and S

- 3 with A

- 2, A

- 3, and A

- 4

(mist eliminators), respectively. [Basis: 93102.4(b)]

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

from A

- 2, A

- 3, and A

- 4 with A

- 1 wet scrubber.

[Basis: 93102.4(b)]

The ventilation and abatement system shall be properly

maintained and kept in good working condition.

c) The owner/operator uses Bayowet FT

- 248 chemical fume

suppressant bath additive to assist in housekeeping

efforts around the plating tank. The plating bath

surface tens ion 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 own er/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 demonstr ate 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 perf orm source tests to

demonstrate compliance according to the following

schedule:**AN 19107/BBC (Plant A4019)**

**RE Frazier, P.E.**

**11/13/2008**

6 i. Unless Part 3.b)ii. is satisfied, subsequent

source testing shall be p erformed 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,

t hen 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 operat ion 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) 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 t he 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.

e) 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]**AN 19107/BBC (Plant A4019)**

**RE Frazier, P.E.**

**11/13/2008**

7 f) 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

u nder 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. Houseke eping

The following housekeeping requirements shall be

implemented to reduce potential hexavalent chrome

fugitive emissions: [Basis: 93102.5(c)]

a) Chromic a cid 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 liq uid 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. hand ling 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 ret urned 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 day s 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 polish ing areas shall be

separated from the chrome plating operation by a

physical barrier, which may include, but is not

limited to vertical plastic strip curtains.

g) Chromium containing wastes generate d as a result of**AN 19107/BBC (Plant A4019)**

**RE Frazier, P.E.**

**11/13/2008**

8 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 m aintained

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

Wet Scrubber. The pressure drop shall be maintained

within plus or minus 2 inches of water of the value

established durin g 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 opera ting 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 opera tion. 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 revi sions 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

and maintenance for the chrome plating operation,

including steps to be taken to correct operating**AN 19107/BBC (Plant A4019)**

**RE Frazier, P.E.**

**11/13/2008**

9 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.

[ 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

c ondition 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 rec ords 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 own er/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 Wet Scrubber pressure drop

at least once per operating week.

c) Breakdown Reco rds noting the occurrence,

duration, cause (if known), and action taken.

d) Records of excesses of the emission or ampere

- hour

limits of Part 1, the surface tension

limits of Part 2, or the pressure d rop limits

established under Part 6.b).

e) Housekeeping Records demonstrating compliance

with Part 5, above, including date and time of

housekeeping activity.**AN 19107/BBC (Plant A4019)**

**RE Frazier, P.E.**

**11/13/2008**

10 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

mai ntained 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 Compli ance 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 signa ture of the responsible official who

is certifying the accuracy of the report.

[Basis: 93102.13(c)]