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 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 6471 6471 Bayowet FT248A-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 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.
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RE Frazier, P.E.

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Basis Throughput, a-hr/yr Factor, mg/a-hr Emissions, 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 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, 0.58 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 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 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
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 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 eliminator and A-1 wet scrubber. 

 3) Emission Limits 

 Emissions of hexavalent chromium shall not exceed 0.006

 mg/amp-hr after abatement. 

 4) Surface Tension 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

 hours 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 indicate

 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
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 system (after abatement) 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. 

 Source 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 maintained. 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 procedure, documentation of

 calculations, and surfactant chemical addition

 quantities. 

 Retention of Records: All records shall be kept and

 maintained for a period 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 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
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 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 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, 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 the 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 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: 
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 i. Unless Part 3.b)ii. is satisfied, subsequent

 source testing shall be performed no later

than 36 months after the date of the previous

District-approved source test demonstrating

compliance.

 ii. If the previous two consecutive source tests

 demonstrate compliance, the subsequent tests

 shall be performed no later than 48 months

after the previous source test.

 iii. If a source test demonstrates non-compliance,

 then the owner/operator must perform another

source test to demonstrate compliance.

Subsequent source tests to demonstrate

compliance shall be performed no later than

24 months after the previous source test. If

after two consecutive source tests at the 24

month frequency, both of which demonstrate

compliance, the source test frequency reverts

to the original schedule in Part 3.b)i. 

 c) Non-compliant source test: After conducting a

 source test which demonstrates non-compliance the

 owner/operator shall review and adjust or repair the

 plating operation and associated emission control

 system. A source test to demonstrate compliance

 shall be performed no later than 30 days after the

 chrome plating system adjustments/repairs are

 completed. 

 d) 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. 

 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] 
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 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

 under the direction of the owner or operator or current

 employee who is onsite and has completed the ARB

 Compliance Assistance Training Course for chrome

 plating and anodizing. [Basis: 93102.5(b)] 

 5. Housekeeping 

 The following housekeeping requirements shall be

 implemented to reduce potential hexavalent chrome

 fugitive emissions: [Basis: 93102.5(c)] 

 a) Chromic acid materials shall be stored in a closed

 container in an enclosed storage area. 

 b) Chromic acid materials shall be transported from

 storage to the bath in a closed container. 

 c) Any liquid or sold hexavalent chrome containing

 material that is spilled shall be contained or

 cleaned up within one hour after being spilled. 

 d) Dragout shall be minimized by: 

 i. handling the plated parts so that chromic acid

 is not dripped outside the tank, and

 ii. installing splash guards at the tank to

 minimize overspray and to ensure that chrome

solution is returned to the tank. 

 e) Surfaces within the chrome storage area and the

 walkways and other areas potentially contaminated

 with hexavalent chrome, shall be cleaned at least

 one time every seven days by either HEPA vacuuming,

 damp cloth hand wiping, wet mopping, use of non-

 toxic dust suppressants or any other District-

 approved method. 

 f) Buffing, grinding or polishing areas shall be

 separated from the chrome plating operation by a

 physical barrier, which may include, but is not

 limited to vertical plastic strip curtains. 

 g) Chromium containing wastes generated as a result of
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 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

 Wet Scrubber. 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] 

 b) A checklist to document the inspection, operation

 and maintenance for the chrome plating operation,

 including steps to be taken to correct operating
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 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

 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 Wet Scrubber 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

 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. 
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 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)]