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 a nd 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 th e 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 Bat h Control Abatement

- 1 Abatement

- 2

8 2 7579 7579 None A

- 41

Mapco/HEPA n/a

9 3 “ “ “ 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

- 4 03:

**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. F or 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 requi re 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 CALC ULATIONS

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 1 14,500,000 0.006 1.51

Post

- ATCM 114,500,000 0.0015 0.378

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

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 applicable.

5. EXEMPTIONS

There are no applicable exemptions.

6

. OFFSETS

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

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 s hould 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 th e 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

3 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 L imit)

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, Secti on 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 compli ance. 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 shal l 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 1 1

- 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 yea rs. 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 Divisi on 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 sourceAN 19114/USS Posco (Plant A2371)

RE Frazier, P.E.

11/13/2008

4 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, unle ss

otherwise noted.

1. Performance Standards

a) Emission Limits effective through 10

- 23

- 2009:

Emissions of hexavalent chromium shall not ex ceed

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 ex ceed

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 mi llion

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 per iods

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

5 3. Source Test

a) The owner/operator shall perform a source te st 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 lon g 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

demonst rate 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 a nother

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 sourceAN 19114/USS Posco (Plant A2371)

RE Frazier, P.E.

11/13/2008

6 te st 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

a s 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

te sting 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 ele ments: 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 adva nce 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 so urce

test. [Basis: 93102.7]

4. Training

No later than October 24, 2009, and within every two

calendar years thereafter, the owner or operat or 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 b e

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 contaminatedAN 19114/USS Posco (Plant A2371)

RE Frazier, P.E.

11/13/2008

7 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

amper e

- 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 & Main tenance (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 reque st. 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

8 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 Frequ ency

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 an d 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 accord ance 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 descript ion 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 parametersAN 19114/USS Posco (Plant A2371)

RE Frazier, P.E.

11/13/2008

9 established under Part 6 noting any e xceedances 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 n o

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 Com pliance 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 y ear.

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 si gnature of the responsible official who

is certifying the accuracy of the report.

[Basis: 93102.13(c)]