ENGINEERING EVALUATION REPORT

PLANT NAME USS Posco Industries, Inc

APPLICATION NUMBER 19114

PLANT NUMBER 2371

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

82 7579 7579 None A-41

Mapco/HEPA

n/a

93 “ “ “ A-42 

Mapco/HEPA

“

155 “ “ “ A-41 

Mapco/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 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 114,500,000 0.006 1.51

Post-ATCM 114,500,000 0.0015 0.378

Net Difference 0 0.0045 1.13
AN 19114/USS Posco (Plant A2371)

RE Frazier, P.E.

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, 1.51 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 7579 is presented in this application, as is the revised Condition 

7579.

10. RECOMMENDATIONS

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

Condition 7579.

OLD CONDITION 7579

 COND# 7579 --------------------------------------

 For S82, 93, 155 - Electro-Tinning Lines: 
AN 19114/USS Posco (Plant A2371)

RE Frazier, P.E.

11/13/2008

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 1. Throughput 

 The total annual combined throughput at sources S82,

 S93, and S155 shall not exceed 114.5 million amp-hr in

 any consecutive twelve month period.

 (Basis: Voluntary Limit) 

 2. Abatement 

 This source shall not be operated unless emissions are

 vented to either A41 or A42, Mapco Enforcer III High

 Efficiency Scrubber.

 (Basis: Regulation 11-8, Section 93102 (c)(2)) 

 3. Emission Limits 

 Emissions of hexavalent chromium shall not exceed 0.006

 mg/amp-hr after abatement.

 (Basis: Regulation 11-8, Section 93102 (c)(2)) 

 4. Source Test 

 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.

 (Basis: Regulation 11-8, Section 93102 (d)(4)) 

 5. Record Keeping 

 To comply with the above parts, monthly records of

 current applied to this source integrated over time, in

 units of amp-hrs, and records of chemical addition to

 the source shall be kept (onsite) and maintained. Such

 records shall be submitted to the BAAQMD on an annual

 basis via the annual update program. These records

 shall be maintained at the plant site for at least five

 years.

 (Basis: Regulation 11-8, Section 93102 (h)(4)(A)) 

 6. In order to demonstrate compliance with the emission

 limit is part 3, the owner/operator of this equipment

 shall conduct District approved source testing of both

 scrubber systems every two years. The initial source

 test required by this part shall be conducted no later

 than July 1, 2004. Subsequent testing shall be performed

 no later than 24 months from the previous test. The

 Director of the Compliance and Enforcement Division of

 the District shall be contacted to obtain approval of

 the source test procedures at least 14 days in advance

 of each source test. The Director of the Compliance and

 Enforcement Division shall be notified of the scheduled

 test date at least 7 days in advance of each source
AN 19114/USS Posco (Plant A2371)

RE Frazier, P.E.

11/13/2008

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 test. The source test report shall be submitted to the

 Compliance and Enforcement Division and to the Director

 of the Compliance and Enforcement Division within 45

 days of the test date.

 (basis: Regulation 2-1-304)

NEW CONDITION 7579

COND# 7579 --------------------------------------

 Application 18718 (September 2008): Addition of HEPA

 Filters to A-41 and A-42 Mapco Enforcer III Units. The

 owner/operator shall comply with the following

 Conditions for Sources 82, 93 and 155 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

 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 combined throughput at

 S-82, S-93, and S-155 shall not exceed 114.5 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-82, S-93, and S-155 with plating tank

 emissions vented through A-41 and/or A-42. A-41 and

 A-42 are identified as Mapco Enforcer III Scrubber

 units with HEPA filtration elements. 

 The ventilation and abatement system shall be properly

 maintained and kept in good working condition. 
AN 19114/USS Posco (Plant A2371)

RE Frazier, P.E.

11/13/2008

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 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: 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

 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
AN 19114/USS Posco (Plant A2371)

RE Frazier, P.E.

11/13/2008

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 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-41 & A-42 Mapco Scrubber unit(s): record

 pressure drop at least one time every 15

minutes of operation.

 ii. A-41 & A-42 HEPA filter elements: 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

 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, 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) Surfaces within the chrome storage area and the

 walkways and other areas potentially contaminated
AN 19114/USS Posco (Plant A2371)

RE Frazier, P.E.

11/13/2008

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 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. 

 e) 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-41/A-42 Mapco Scrubber Pressure Drop: The

 owner/operator shall continuously monitor the

 pressure drop across A-41 and A-42 Mapco Enforcer

 III Scrubber unit. 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) A-41/A-42 HEPA Filter Element Pressure Drop: The

 owner/operator shall continuously monitor the

 pressure drop across A-41 and A-42 HEPA filter

 elements. 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,

 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: 
AN 19114/USS Posco (Plant A2371)

RE Frazier, P.E.

11/13/2008

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 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

 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 and conduct wash downs of the

 Mapco Enforcer III unit per manufacturer

 recommendations. [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 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
AN 19114/USS Posco (Plant A2371)

RE Frazier, P.E.

11/13/2008

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 established under Part 6 noting any exceedances of

 the ampere-hour throughput or pressure drop limits.

 e) Housekeeping Records demonstrating compliance

 with Part 3, 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)]