From: Edwin Pupka [EPupka@aqmd.gov]

Sent: Friday, January 21, 2011 12:53 PM

To: Adams, Lucy H.

Cc: Marinshaw, Richard; Fred Lettice; Mohan Nagavedu; David Jones; Rachel Mendoza; Lisa

Gonzales

Subject: California Air Resources Board ‐ January 2009, Chrome Plating Report

Attachments: SouthCoastChromePlatingReport2009.pdf

Lucy,

As requested, attached for your information and review is the subject CARB report relating to their prior

field study relating to the compliance status of chrome plating facilities located within AQMD’s regional

jurisdiction.  Note that this report is also on CARB’s website related to chrome plating rule development

and current activities.

Please call me if you have questions or require additional information.  Ed

Edwin L. Pupka

Senior Enforcement Manager

Engineering & Compliance  

Air Toxics/Haz Mat & Refinery/Energy Team

Office 909.396.3332

FAX  909.396.3817
Compliance Status of 

Chrome Plating Facilities in the

South Coast Air Basin 

Prepared by the 

California Air Resources Board 

Stationary Source Division 

January 2009 
Compliance Status of Chrome Plating Facilities in the 

South Coast Air Basin 

Primary Authors

Jill Locke 

Eric Patton, P.E. 

Field Inspectors

Air Resources Board South Coast AQMD

Michael Donnelly John Anderson 

Steve Eve Gale Jones 

Jill Locke Christopher Ravenstein 

Eric Patton, P.E. Walter Shen 

Reviewed by

Hardip Judge, Manager 

Program Review Section 

Jorge Fernandez, Chief 

Program Evaluation Branch 

Robert Fletcher, Chief 

Stationary Source Division 

Acknowledgements 

The staff of the California Air Resources Board (ARB) wishes to thank the staff 

and management of the South Coast Air Quality Management District (SCAQMD) 

for their support and participation in this project. South Coast AQMD staff John 

Anderson, Gale Jones, Christopher Ravenstein, and Walter Shen participated in 

the field inspections with ARB staff and were instrumental in developing the 

findings contained in this report. Special thanks to Mohan Nagavedu of the South 

Coast AQMD for coordinating this project and for his assistance in developing this 

report. Also, we greatly appreciate the support and guidance provided by 

Ed Pupka and David Jones of the SCAQMD. 
I - 1 

I. Introduction 

This report presents an analysis of the current compliance status of Chrome 

Plating and Chromic Acid Anodizing facilities operating in the South Coast Air 

Basin. Report results are based on recent joint inspections performed by South 

Coast Air Quality Management District (District) and Air Resources Board (ARB) 

staff. Inspections were conducted at 71 facilities. This represents approximately 

50 percent of the permitted inventory of the District. Each inspection involved a 

complete walk through of the facility, review of records, and sample collection 

when deemed appropriate. ARB staff prepared an inspection form which listed all 

the Airborne Toxic Control Measure for Chromium Plating and Chromic Acid 

Anodizing Facilities (ATCM) requirements to document inspection findings. The 

District uses an inspection form to determine compliance with their Rule 1469 in 

conjunction with a checklist for ATCM requirements. Refer to Attachment A for a 

copy of ARB and District inspection forms. 

2. Background 

Chrome platers are currently regulated by the requirements of the governing 

ATCM to control hexavalent chromium which is an extremely hazardous human 

carcinogen. The amendments to the ATCM for Chrome Plating and Chromic 

Acid Anodizing facilities were approved by the Air Resources Board (Board) at 

the December 7, 2006 hearing and became legally effective on October 24, 2007. 

In Resolution 06-25, in which the amendments were approved, the Board 

directed staff to report back to them in 18 months on compliance with the ATCM. 

Findings from this study along with data generated from other districts will form 

the basis of our report to the Board. 

The amended ATCM incorporates new control strategies such as housekeeping 

measures. Some of the regulatory requirements have become effective since 

April 2008. Other requirements, involving control equipment and associated 

source testing to verify compliance limits, will become effective between 

October 2009 and 2011 based upon proximity to sensitive receptors and 

permitted throughput. 

3. Benefits of Study 

Results obtained from this study allowed us to obtain real data and determine if 

operators are on track to meet their respective emission control requirements. 

The results should help the District in planning for resources to meet the 

forthcoming permitting and source test workload necessary to comply with the 

requirements of the ATCM. The inspections also provided the District staff the 

opportunity to explain to the source the upcoming milestones and available 

compliance alternatives. 
I - 2 

Similar studies were conducted in the Bay Area, San Joaquin Valley, and San 

Diego air districts. These three districts, along with South Coast represent about 

90 percent of the permitted chrome plating facilities in the State. 

4. Discussion of Results 

The District inspects chrome platers on a quarterly basis. Inspections include 

verification of compliance with the requirements of District Rule 1469 and the 

governing ATCM. This report only presents results with respect to compliance 

with the governing ATCM. 

 A. Overall Compliance 

Overall compliance of inspected facilities is very high. The inspection of 71 

facilities did not provide any non-compliance scenarios which would have 

necessitated the issuance of violation notices resulting in enforcement action. 

Almost one third of the facilities were in full compliance. However, approximately 

69 percent of the facilities inspected were issued a Notice to Comply under the 

District’s Minor Violation Rule. Almost all the minor violations documented were 

related to the Housekeeping requirements of the ATCM which have become 

effective since April 2008. Refer to Attachment B for detailed inspection results. 

We attribute the current high rate of compliance to quarterly inspections 

conducted by the District, training and outreach, enforcement deterrence, and the 

fact that chrome plating regulations have been in place for over 15 years. For 

historical perspective, chrome plating inspections conducted in 2000 showed full 

compliance only at 28 percent of the facilities. This increased to 78 percent in 

2003 and is currently 100 percent using absence of major violations as a 

measure of comparison. 

The Table below gives compliance statistics for the 71 facilities inspected. 

Compliance Status Number 

of 

Facilities 

Inspected 

Comments 

Full Compliance 22 

Major Violation 0 

Minor Violation 

(Housekeeping Related) 

43 -Inadequate Housekeeping 

Records - 30 instances

-Minor spills/drips, improper 

cleaning schedule - 11 instances 

-Install or extend 

drip trays - 11 instances 
I - 3 

-Install, repair, or extend 

splash guard - 11 instances 

-Inadequate or no barrier 

between grinding and 

plating area - 8 instances 

Minor Violation 

(Non - Housekeeping) 

6 -No copy of Operation and Maintenance 

(O&M) plan onsite -3 instances 

-Surface tension not done 

 weekly - 1 instance 

-No copy of Ongoing Compliance Status 

Report (OCSR) onsite - 2 instances 

Total Facilities Inspected 71 

 

B. Compliance with Traditional Requirements

Compliance with the traditional requirements of fume suppressant addition for 

surface tension, maintenance and operation of control equipment, source testing, 

and other requirements related to monitoring, recordkeeping, reporting, training, 

etc. is very good. Facilities have good familiarity with the traditional requirements 

which were part of the original ATCM and enforced generally through District 

Rule 1469. 

C. Compliance with new ATCM Requirements Currently in Effect

Compliance with some of the requirements which are currently in effect is as 

follows: 

1) Distance to Sensitive Receptor – This along with permitted throughput is a 

key piece of data which dictates the level of control and compliance 

timeline of a plating facility. The ATCM requires this data to be submitted 

to the District by November 2007. All sources have submitted this data to 

the District. The District has cross checked this data and maintains a list 

of all permitted sources with this information. During inspections, distance 

to sensitive receptors was checked against information provided by the 

facilities and found to be correct. 

2) Use of Correct Chemical Fume Suppressant – This requirement has been 

in effect since April 2008 and requires sources to use specific chemical 

fume suppressants listed in the ATCM at specified surface tensions. All 

facilities inspected were using approved chemical fume suppressants and 

aware of the surface tension requirement. Samples of bath solution were 

taken from four facilities, tested by the District laboratory and found to be 

in compliance. 
I - 4 

3) Physical Housekeeping Requirements – These requirements are in effect 

since April 2008 and are described in Section 93102.5(c) of the ATCM. 

Compliance with the housekeeping requirements of the ATCM is an area 

which will need improvement. Forty-three of the 71 facilities inspected had 

at least one housekeeping issue and were issued notices to comply (NTC) 

pursuant to the District’s Minor Violation Rule. Refer to Attachment C for 

photographs giving examples of good compliance (or lack of) in this area. 

All facilities were in compliance with the housekeeping requirements 

related to storage and transport of chromic acid flakes and handling of 

chromium waste. Housekeeping areas which need improvement are 

described below. 

a. Some facilities were found to have minor chromic acid spills/drips or 

did not have a proper cleaning schedule. 

b. Eleven facilities needed to install or extend drip trays to minimize 

dragout. 

c. Eleven facilities needed to install, repair, or extend splash guards at 

the tank to minimize overspray. 

d. The ATCM also requires facilities to separate buffing, grinding, or 

polishing areas from the plating area by means of a physical barrier. 

Only about 10 percent of the facilities inspected had an inadequate 

or no barrier between the grinding and plating areas. 

 

4) Recordkeeping Associated with Housekeeping Requirements – 30 of the 

71 facilities inspected had inadequate housekeeping records. The District 

is working with the sources in this regard and giving them forms which can 

be used to comply with this requirement. 

 

5) Training – All sources inspected had received training from the District. 

6) Other Records – All sources are in compliance with the requirements for 

preparing an Initial Inspection Compliance Status Report, Inspection and 

Maintenance Plan, and Ongoing Compliance Status Report. Notices to 

Comply were issued to five sources because the plans were not found on 

the premises. 

 

D. Compliance with Future ATCM Requirements 

None of the 71 facilities inspected in this study can currently comply with 

emission limits solely through use of fume suppressants. Inspected facilities will 

have to meet the emission limit of 0.0015 milligram/ampere-hour by installing an 

add-on control device by October 24, 2009, 2010, or 2011. The effective dates 

will depend upon sensitive receptor distance and annual permitted ampere-hours. 

Fortunately, 56 percent of the facilities inspected (39 out of 71) are already 

operating with permitted add-on controls. Fifteen of these facilities have valid 

source tests and will not require any further action to meet the upcoming 
I - 5 

compliance dates. Twenty four facilities will require source testing to verify 

emission limits because they have never been source tested, failed the test, or 

because the tests were performed before January 2000. 

Thirty-two of the 71 facilities inspected will require add-on controls and source 

tests to demonstrate compliance with the emission limits. For most of these 

facilities, the compliance date is October 24, 2009. Facilities were reminded that 

the process of obtaining quotes, engineering and installation, permit processing, 

and source testing the system could make it a challenge to meet this deadline. 

Projecting the data to the entire District inventory (of 140 active sources), we 

anticipate 64 facilities would need to install add-on controls and go through the 

permitting and source testing processes. This number could be reduced by a few 

facilities if sources reduce permitted ampere-hours and become eligible for using 

chemical fume suppressants as the sole source of control. 

The Table below summarizes the status of facilities with respect to control 

requirements based on this study. 

Controls 

(Deadline) 

Status Number 

of Facilities 

ATCM Prescribed 

Chemical Fume 

Suppressants 

(April 2008) 

-These are the facilities which can 

show compliance under the current 

District rule by using chemical fume 

suppressants. 

-These facilities are using the correct 

chemical fume suppressant and 

maintaining surface tension per ATCM. 

32 

Use ATCM Prescribed 

Chemical Fume 

Suppressants to Control 

Emissions 

(varies from 10/2009 to 

2011) 

These facilities would have a 

throughput <= 50,000 amp-hr/yr if 

located more than 330 feet from a 

sensitive receptor. For facilities less 

than 330 feet the throughput would be 

limited to <= 20,000 amp-hr/yr. 

0 

Comply with 0.0015 

mg/amp hr limit 

(varies from 10/2009 to 

2011 based on 

throughput and receptor 

distance) 

-No controls required other than 

chemical fume suppressants 

-Have permitted controls and have 

passed source test 

-Have permitted controls but need to 

pass source test 

-Obtain permits, install controls, and 

pass source test 

0 

15 

24 

32 

Total Facilities Inspected 71 
I - 6 

 

5. District Timeline for Modifying Rule 1469 

The District recently amended Rule 1469 – Hexavalent Chromium Emissions 

from Chrome Plating and Chromic Acid Anodizing Operations to incorporate the 

more stringent requirements of the State ATCM. A public workshop regarding 

Proposed Amended Rule (PAR) 1469 was conducted on October 2, 2008. The 

District’s Governing Board subsequently approved PAR 1469 on 

December 5, 2008. 

6. Status of Current Permits

The District has mailed compliance advisories to all sources to inform them of 

new requirements. However, current facility permits do not incorporate latest 

requirements from the ATCM. We recommend that the District incorporate the 

latest air toxic control measure/rule requirements as permit conditions. 

7. Recommendations 

The District should follow-up on the housekeeping issues discovered during the 

inspections. All other areas were found to be in high compliance and do not 

require any special attention other than routine inspections. 

The District should be prepared for the upcoming permitting and source testing 

workload related to the approximately 64 facilities which may require additional 

controls. Another 40 to 50 sources will need to be source tested. 

Some of the sources are small businesses and may require additional help in 

understanding available compliance options. 

All permits should be modified to include the latest Rule 1469 requirements as 

permit conditions. 

The District should revise Notice of Violation/Notice to Comply Guidelines for 

Rule 1469 to incorporate new housekeeping related requirements. 
Attachment A 

Inspection Forms 

ARB Inspection Form for ATCM 

SCAQMD Inspection Form for Rule 1469 

SCAQMD Inspection Form for ATCM 
ARB Inspection Form for ATCM 

Chrome Plating & Chromic Acid Anodizing ATCM Compliance Evaluation 

Facility: _________________ ID # ______ Address: ____________________________ Contact: ________________ Title: ______________ P

Inspectors: _____________/______________ Date: ___________ Time: __________ PTO #’s: __________________ Expires: ___________ P

Principal Products Produced: _______________________ Last Inspection: __________ Equipment Operating Now: _____ # of Permitted Units 

(1) Distance to the nearest sensitive receptor shall be provided to the permitting agency by November 24, 2007 [Section 93102.4(b)(2)]: D

a. Based on the distance measurement, is the facility complying or preparing to comply with the emission limitations in Section 93102. application for a permit to construct, purchasing an add-on control device, preparing to do a performance test or using the chemical f

 93102.8? ___________________________________________________________________________________________________

(2) Emission Limits for Existing Hard & Decorative Chrome Plating & Chromic Acid Anodizing Facilities After October 24, 2007 [Sectio

Sensitive Receptor Distance Annual Permitted Ampere-Hours Emission Limitation Effective 

 < 330 Feet < 20,000 Use Fume Suppressants April 24, 

 in section 93102.8  > 330 Feet < 50,000 Use Fume Suppressants April 24, 

 in section 93102.8  < 330 Feet > 200,000 0.0015 mg/ampere-hour October 2

 after add-on control device  > 330 Feet > 500,000 0.0015 mg/ampere-hour October 2 after add-on control device  < 330 Feet > 20,000 & < 200,000 0.0015 mg/ampere-hour October 2

 after add-on control  > 330 Feet > 50,000 & < 500,000 0.0015 mg/ampere-hour October 2(3) Emission Limits for Modified Hexavalent Chrome Plating & Anodizing Facilities [Section 93102.4(c)]:  a. Using an add-on control device? ________________________________________________________________________________ b. Meeting an emission limit of 0.0015 mg/ampere-hour? ______________________________________________________________(4) Emission Limits for New Hexavalent Chrome Plating & Anodizing Facilities Beginning October 24, 2007 [Section 93102.4(d)]:  a. Located at least 1,000 feet from the boundary of any area zoned mixed use or any school? __________________________________

 b. Using a HEPA add-on control device? ___________________________________________________________________________

 c. Measured emission rate is no more than 0.0011 mg/ampere-hour? _____________________________________________________ d. Risk analysis conducted prior to start-up? _________________________________________________________________________ e. Demonstrating compliance using an alternative method? _____________________________________________________________

(5) Requirements for small hard chrome plating facilities using less than or equal to 500,000 ampere-hours per year [93102.4(a)(1)(C)]:  a. Facility must use a chemical fume suppressant specified in section 93102.8 and maintain the surface tension below the value specifie

 b. The facility must comply with the monitoring, recordkeeping and reporting requirements contained in the ATCM: _______________

Pg 1 of 4 
(6) Environmental Compliance Training [Section 93102.5(b)]: 

a. No later than October 24, 2009, chrome plating & chromic acid anodizing shall only be conducted by an operator or current employe

completed ARB’s Compliance Assistance Training Course pertaining to chrome plating & chromic acid anodizing: 

Name Title Date Course Completed 

 _____________________ ____________________ ____________________ 

 _____________________ ____________________ ____________________ (7) Housekeeping Requirements [Section 93102.5(c)]: a. Chromic acid flakes shall be stored in a closed container in an enclosed storage area: ______________________________________

 b. Chromic acid powder or flakes shall be transported from an enclosed storage area to the chrome plating baths in a closed container: _

 c. Any liquid or solid material that may contain hexavalent chromium that is spilled shall be cleaned up or contained within one hour af d. Drip trays shall be installed between automated tank lines to minimize dragout: __________________________________________ e. Splash guards shall be installed at the tank to minimize overspray: _____________________________________________________

 f. Surfaces within the enclosed storage area, open floor area, walkways around the tanks or any surface that potentially accumulates dus

 every seven days: ____________________________________________________________________________________________

 g. Buffing, grinding or polishing areas within the facility shall be separated from the plant or anodizing operation by a physical barrier 

 plastic strip curtains: _________________________________________________________________________________________ h. Chromium waste generated from housekeeping shall be stored, disposed of, recovered or recycled using practices that do not lead to 

(8) Facilities using a Trivalent Chromium Bath or Enclosed Tanks [Section 93102.6]:  a. Facilities shall control total chromium emissions using an add-on control device (< 0.01 mg/dscm) or chemical fume suppressant:___

 b. New facilities shall conduct a facility wide site specific risk analysis: ___________________________________________________

 c. Facilities using enclosed tanks shall control emissions by using an add-on control device (0.015 mg/dscm) or chemical fume suppres(9) Performance Test Requirements [Section 93102.7]: 

a. Existing facilities demonstrating compliance with a mg/ampere-hour emission limit; facilities undergoing a modification after Octob

 facilities that submit an alternative compliance method; shall conduct a performance test using one of the approved test methods spec

 Date Test Conducted: ________________________ Test Method: _________________________ 

(10) Chemical Fume Suppressants [Section 93102.8]: 

a. Facilities using chemical fume suppressants to comply with an emission limit shall use one of the following approved chemical fume 

 specified surface tensions: 

Chemical Fume Suppressant Stalagmometer Measured Surface Tension 

(dynes/centimeter) 

Tensiometer M

(dyn

Benchbrite CR 1800 

Benchmark Products 

< 40 

Clepo Chrome 

Macdermid 

< 40 

Fumetrol 140 

Atotech U.S.A. 

< 40 

HCA-6.2 

Hunter Chemical LLC 

< 32 

HCA-4 

Hunter Chemical LLC 

< 32 

Pg 2 of 4 
(11) Parameter Monitoring Requirements [Section 93102.9]: 

 a. Ampere-hours: each tank shall have a continuous recording, non resettable meter that is hard-wired: __________________________

 b. Pressure Drop: pressure drop shall be maintained within plus or minus 2 inches of water established during the performance test for c scrubber or fiber-bed mist eliminator: ____________________________________________________________________________

 The pressure drop shall be maintained with (-) 1⁄2 times to + 2 times the inches of water of the value establish during the performance 

 with the emission limitation for HEPA filters: _____________________________________________________________________

c. Inlet Velocity Pressure: the inlet velocity of a packed-bed scrubber shall be monitored with a mechanical gauge and be maintained w

 the value established during the performance test: __________________________________________________________________

 d. Surface Tension: shall be monitored daily for 20 operating days and weekly thereafter as long as there is no violation of the surface t If a violation occurs, the measurement frequency shall return to daily for 20 operating days and weekly thereafter: _______________ e. Foam Blanket Thickness: foam blanket thickness shall be maintained at the thickness established during the performance test and me

 days and daily thereafter as long as there is no violation of the foam thickness requirement: _________________________________ If a violation occurs, the measurement frequency shall return to hourly for 15 operating days and daily thereafter: _______________

(12) Inspection & Maintenance Requirements [Section 93102.10]:  a. Does the facility comply with the inspection & maintenance requirements of the ATCM? ___________________________________(13) Operation & Maintenance Plan Requirements [Section 93102.11]:  a. Facilities subject to Section 93102.10 shall prepare an operation and maintenance plan and keep the plan available for inspection: ___

(14) Recordkeeping Requirements [Section 93102.12]: a. The owner/operator shall maintain the following records:  Inspection Records: ____  Performance Test Records: ____  Monitoring Data Records: _____  Cumulative Rectifier Usage: ____  Pressure Drop: _____  Inlet Velocity Pressure: _____  Surface Tension: _____  Mechanical Fume Suppressants: _____  Foam Blanket Thickness: _____  Breakdown Records: _____  Records of Excesses: _____  Records Demonstrating Facility Size: _____  Annual ampere-hour usage: _____  Chemical Fume Suppressant Additions: _____  Trivalent Bath Components: _____  New/Modified Source Review Information: ______  Housekeeping Records: ______  b. Records shall be maintained for five years and at least two years on site: ________________________________________________

(15) Reporting Requirements [Section 93102.13]:  a. The owner/operator shall notify the district of their intention to conduct a performance test: _________________________________

 b. The owner/operator shall submit an Initial Compliance Status Report each time they become subject to the requirements of the ATCM

Pg 3 of 4 
 c. The owner/operator shall submit an Ongoing Compliance Status Report to the district on or before February 1st annually: _________

 d. The owner/operator shall report breakdowns to the district according to the breakdown rule: ________________________________

 e. Facilities using Trivalent Chromium using a wetting agent shall submit a report to the district no later than November 24, 2007: ____

(16) Permit Conditions:  Does this facility violate any of its permit conditions? ____________________________________________________________________________________________________________________

____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________(17) Compliance Determination: 

Source (PTO #) Violation ER / NER Regulation 

(18) Comments and Observations: 

Pg 4 of 4
SCAQMD R1469 CHROME PLATING INSPECTION REPORT Pg 1 of 2

COMPANY NAME INSPECTION DATE 

ADDRESS FACILITY ID# 

CONTACT NAME PHONE #

number of plating tanks HARD []______(l/m/s) DECORATIVE []_______ANODIZING []______TRIVALENT 

[]______ 

REQUIREMENTS R1469 YES NO

• Multiple rectifiers serve a chrome plating tank or multiple chrome plating tanks [] [] 

• Installed a dedicated, hard wired amp-hr meter on each chrome plating rectifier c2 [] [] 

• Amp-hr meters are operational, totalizer, and non-resettable c2 [] [] 

• Shunt(s) between the amp-hr meter/rectifier electrical circuit(s) are calibrated annually [] [] 

• Logs daily plating current used in each plating tank (amp-hr/day) j4A [] [] 

• Complies with facility plating current limit in permit condition. Permit # & limit [] [] 

• Inspect and maintain the amp-hr meter and Stalagmometer/Tensiometer per Table 4 h2 [] [] 

• Uses AQMD certified wetting agents, name brand: c3 [] [] 

• Air-sparging occurs during chrome tank non-operation or while chromic acid is being added c4 [] [] 

• Implemented housekeeping practices to ensure no fugitive chrome emissions c5 [] [] 

• Operating APCE installed prior to May 2003 c6 [] [] 

• Vents all HARD CHROME plating tank(s) to APCE c7 [] [] 

• Facility is located 25 m or less from a sensitive receptor or residence, or 100 m or less from a school (K-12) c8 [] [] 

• Chrome tanks are vented to APCE that meets a chrome emission limit of 0.0015 mg/amp-hr/tank c8A [] [] 

• Complies with an alternative compliance option as specified in subdivision R1469(d) c8B [] [] 

• Facility is located more than 25 m from a sensitive receptor or residence c9 [] [] 

• Circle facility daily operating schedule > 12 or < 12 hr/day _______________________________________________ [] [] 

• Chrome tanks are vented to APCE that meets an emission limit of 0.01 mg/amp-hr/tank c9Ai [] [] 

• Chrome tanks are vented to APCE that meets an emission limit of 0.0015 mg/amp-hr/tank c9Aii [] [] 

• Complies with an alternative compliance option as specified in subdivision R1469(d) c9B [] [] 

• Conducts multiple chrome plating processes c10 [] [] 

• Source energy consumption is > 1 c10A [] [] 

• Complies with emission limit of 0.01 mg/amp-hr/tank if energy consumption is < 1 c10B [] [] 

• Complies with emission limit of 0.0015 mg/amp-hr/tank if energy consumption is > 1 c10C [] [] 

• Trivalent bath operating with a fume suppressant or vented to APCE. State type of control c11, j10 [] [] 

• Facility staff has current R1469 certified training c12 [] [] 

• Hard chrome operation complies with an interim standard c13 [] [] 

• Hard chrome operation existing before 12/16/93 c13Ai [] [] 

• Hard chrome operation new/modified after 12/16/93 c13Aii [] [] 

• Small hard chrome operation using < 500,000 amp/yr c13Aiii [] [] 

DECORATIVE OR ANODIZING TANKS CHROME EMISSION CONTROLS (c13B)

• Vents emissions to APCE that meet an emission limit of 0.01 mg/dscm c13B [] [] 

• Controls emissions with a mechanical fume suppressant (Foam Blanket, Polyballs, PVC tubes) c13B [] [] 

• Controls emissions with a certified wetting agent(s) Field Check of surface tension measurement f [] [] 

• Complies with Surface Tension limit(s) of 45 dynes/cm or with permit condition limit of ______ dynes/cm f, j4D [] [] 

• Measured and recorded the initial Surface Tension daily for 20 operating days and established a baseline g2, j2-4D [] [] 

• Exceeded the initial surface tension and established a new surface tension baseline g2, j2-4D [] [] 

• Measures and records the Surface Tension weekly with a stalagmometer or tensiometer g2, j2-4 [] [] 

• Sends samples of plating solution to a lab to measure the Surface Tension on a weekly basis g2, j2-4 [] [] 

• Logs the name, manufacturer and volume of wetting agent added to the chrome plating bath g3, j2-9 [] [] 

• Measured and recorded the Foam Blanket Thickness hourly for 15 days. Dates of measurements g3, j2-4 [] [] 

• Measures and records the Foam Blanket Thickness daily. Date of last measurement check g3, j2-4E [] [] 

• Exceeded the initial Foam Blanket thickness and established a new thickness baseline g3, j4E [] [] 

• Inspect mechanical fume suppressant adequately cover the plating tank surface (Polyballs, PCV tubes) g4, j2 [] [] 

• Facility complies with an approved alternative compliance option. Specify compliance option d1 [] [] 

COMMENTS: 

 

 

 
SCAQMD R1469 CHROME PLATING INSPECTION REPORT Pg 2 of 2

PERFORMANCE TEST REQUIREMENTS R1469 YES NO 

• Submitted an EXISTING report of Source Test conducted prior to 7/24/97. Date submitted e2 [] [] 

• Submitted a Source Test Protocol 60 days prior to the source test. Date submitted e4 [] [] 

• Notified AQMD 60 days prior to the source test schedule date. Date submitted k1Ai [] [] 

• Conducted a Source Test within 180 days of plating operations startup. Startup and Test date e1 [] [] 

• Source test was conducted by using approved test methods e3 [] [] 

• Submitted Source Test Results to AQMD within 90 calendar days after the source test. Date submitted k1B [] [] 

• Existing Source Test was approved by AQMD and EPA. AQMD approval status or date k1C [] [] 

• All and each chrome emission point(s) was included in the source test measurement(s) e5 [] [] 

• maintain source test records and initial pressure drop and inlet velocity pressure baseline values j3 [] [] 

 PARAMETER MONITORING for APCE 

Composite Mesh Pad (CMP) [] Packed Bed (PBS) [] CMP/PBS [] Fiber-Mist Eliminator (FME) [] HEPA[] 

• Monitors & Records the pressure drop measured across the APCS weekly (in inches of water). Reading g1A, j4B [] [] 

• Pressure gauges are operating and installed in an accessible and visible area g1A, j4 [] [] 

• Pressure drop reading was established during source test. Reading g1A, j4B [] [] 

• Pressure drop is within +/-1“ of source test reading for CMP, PBS, CMP/PBS or FME g1A, j4B [] [] 

• Pressure drop is within -0.5 to +2 times the source test reading for HEPA filters g1A, j4B [] [] 

• Records the PBS inlet velocity pressure weekly. Reading g1B, j4C [] [] 

• PBS inlet velocity pressure gauge is operating and installed in an accessible and visible area g1B, j4C [] [] 

• PBS inlet velocity pressure reading was established during source test. Reading g1B, j4C [] [] 

• PBS inlet velocity pressure reading is within +/- 10% of source test reading. Reading g1B, j4C [] [] 

• maintain inspection records for the APCE j1ABC [] [] 

• maintain records of maintenance activities performed on the APCE j1D [] [] 

• maintain records of any actions taken to correct deficiencies on the APCE i1E [] [] 

• complies with inspection and maintenance requirements outlined in Table 3 h1 [] [] 

OPERATIONS AND MAINTENANCE PLAN 

• Prepared an OMP (Operation and Maintenance Plan). Date i1 [] [] 

• OMP is incorporated in the facility Tittle V permit i1 [] [] 

• OMP has checklists for operation and maintenance of the APCE, process, and monitors i1A [] [] 

• OMP has procedures to ensure the equipment is properly maintained i1B [] [] 

• OMP is readily available on site for inspection i2 [] [] 

• OMP was modified. Date and reason for modification: i3 [] [] 

• Maintains all OMP revisions for at least 5 years i3 [] [] 

• OMP is adequately revised to minimize breakdowns i4 [] [] 

OTHER RECORDKEEPING REQUIREMENTS – maintains records of: 

• Breakdown records j5, k4 [] [] 

• Exceedances j6 [] [] 

• Facility size j7 [] [] 

• Annual actual cumulative rectifier capacity j7A [] [] 

• Maximum potential cumulative rectifier usage limit j7B [] [] 

• Housekeeping practices j8 [] [] 

• New/modified source information j11 [] [] 

• All records for a 5yrs retention period and for 2 yrs on site to be made available upon request j12 [] [] 

REPORTING – submitted the: 

• Initial Compliance Status Report - Notification # k2 [] [] 

• Annual Ongoing Compliance Status Report for (year) – Notification # k3 [] [] 

• Compliance Plan - Application # c14 [] [] 

COMMENTS: 
ATCM INSPECTION REPORT – EMISSIONS LIMITATIONS 

COMPANY NAME _______________________________ INSPECTION DATE _______________ 

ADDRESS ______________________________________ FACILITY ID# ____________________ 

CONTACT NAME _____________________________________ PHONE # ___________________________

EXISTING (prior to 10/24/07) [ ] MODIFIED (after 10/24/07) [ ] NEW (after 10/24/07) [ ]

REQUIREMENTS PER CHROME ATCM Table 93102.4

• The facility will be subject to new emission limitations during the next 4 years YES [ ] NO [ ]

If NO provide the applicable: 

• Sensitive receptor distance____________________ 

• Annual permitted amp-hr______________________ 

• Emission limitation___________________________ 

If YES provide the applicable: 

• Sensitive receptor distance____________________ 

• Annual permitted amp-hr______________________ 

• Current emission limitation_____________________ 

• Future emission limitation______________________ 

• Future compliance date________________________ 

Will a control device be required YES [ ] NO [ ] 

COMMENTS: _________________________________________________________________________

_____________________________________________________________________________________

_____________________________________________________________________________________

DISPOSITION OC NTC # NOV# DATE 

INSPECTOR SIGNATURE REPORT DATE 

SUPERVISOR SIGNATURE REVIEW DATE 

ATCM inspection checklist Jul 8, 2008.doc Pg 1 of 3 
ATCM CHECKLIST – 2008 

ATCM Requirements For Existing, Modified, and New Chrome 

Plating facilities 

 NC NV OC Other

93102.3a47 checked for sensitive receptors such as residences, preschools, retirement 

and nursing homes, prisons, and dormitories 

 

 sensitive receptor is located < or = 330 feet (100 meters), NAME & 

ADDRESS

 

 sensitive receptor is located > 330 feet (100 meters) 

 determine annual permitted amp-hrs, AMOUNT 

 determine the emission limit requirement per Table 93102.4, LIMIT 

 determine the effective compliance date requirement per Table 93102.4, 

DATE 

 

 

Health Risk Requirements 

 

93102.4 Table 93102.4, superscript 3 - Perform a risk assessment if: 

93102.4b1 existing facility (prior to 10/24/07) with annual chrome emissions are > 15 

grams 

 

93102.4c2 modified facility (after 10/24/07) with annual chrome emissions expecting to 

exceed 15 grams 

 

93102.5a removed add-on controls 

b complied with current ARB/AQMD environmental compliance training 

c implemented housekeeping practices to reduce chrome fugitive emissions 

c1 stored chrome substances in closed containers or enclosed storage area 

c2 transport chrome substances in closed containers from storage to tanks 

c3 cleaned chrome spills or contained spills < 1 hr 

c4 minimized dragout 

c4A installed drip trays in automated lines 

c4B1 prevents dripping outside chrome tanks 

c4B2 installed splash guards to prevent overspray and ensure liquids return to 

chrome tank 

 

c5 maintains surfaces areas, floors, storage, walkways free of chrome 

contamination 

 

c6 installed a curtain or physical barrier to chrome plating from buffing, grinding 

or polishing areas 

 

c7 stores, disposes, recovers or recycles all chrome waste 

93102.7 Performance Test Requirements 

 

a1 conducted performance test to demonstrate compliance with 93102.4 

a1A Existing facilities (prior to 10/24/07) 

a1B Modified facility after 10/24/07 

a1C new chrome facility complying with 93102.4d2 

a1D submitted alternative compliance method for approval per 93102.4b3 (see 

pg 16 of the ATCM) 

 

a2 new or modified facility conducted performance test no later than 60 days 

after initial startup 

 

a3 existing facility will comply with source test date per Table 93102.4, DATE 
ATCM CHECKLIST – 2008 

 

ATCM Requirements For Existing, Modified, and New Chrome Plating 

facilities 

NC NV OC Other 

a4 source test was conducted using an approved test method per 93102.7c, 

DATE

 

 

ATCM Requirements For Existing, Modified, and New Chrome Plating 

facilities 

 

a5 exempt from performance test IF: 

a5 burns < or = 20,000 amp-hr/yr and located <330 ft from sensitive 

receptor and uses a chemical fume suppressant or

 

a5 burns < or = 50,000 amp-hr/yr and located >330 ft from a sensitive 

receptor that exist on 10/24/07, and uses a chemical fume 

suppressant 

 

 

a6 trivalent chrome facilities meeting (emitting) < or = 0.01 mg/dscm 

a6 source test conducted to demonstrate compliance with the 0.01 

b demonstrated compliance with an AQMD approved source test 

93102.8 Chemical Fume Suppressant Requirements 

a uses an approved fume suppressant, NAME 

 measures the surface tension with an stalagmometer, most recent VALUE 

 measures the surface tension with a tensiometer, most recent VALUE 

 adds the circled chemical fume suppressant to the chrome tank Benchbrite, 

Clepo, Fumetrol 140, Hunter HCA-6.2, Hunter HCA-4 

 

 determine from Table 93102.8 if the facility is in compliance and answer 

questions on 1st page of this report 

 

b uses an approved alternative fume suppressant 

b1 tested the alternative fume suppressant under representative operational 

conditions 

 

b2 achieved 0.01 mg/amp-hr rate when source testing the alternative fume 

suppressant 

 

c uses a fume suppressant that is not longer approved by AQMD 

93102.15 Chrome Kits Requirements 

a selling, supplying, manufacturing chrome kits 

b section 93102.5a exemption applies at this chrome plating facility 

c uses a chrome kit for chrome plating 

d uses any associated equipment for chrome plating 

 

OTHER (explain)

ATCM inspection checklist Jul 8, 2008.doc Pg 3 of 3 
Attachment B 

Inspection Results 
 Chrome Plating Joint Inspection Results 

Facility Location Inspection 

Date

Receptor 

Distance 

(feet)

Control Options 

Used

MRR 

Permitted Actual (2007) Splash 

Guards

Drip Trays Gr

B

B

1 CPPG, Inc 3911 E. Miraloma, 

Anaheim

7/15/2008 

JL/JA

974 148.9 million 21,528,797 Mist Eliminator 

HEPA, FoamLok L, Polyballs 

Yes No splash 

guard

NA Plas

2 Classic Plating 2885 E. Miraloma, 

Anaheim

7/15/2008 

JL/JA

> 330 2,917,000 724,370 Mist Eliminator 

HEPA, Fumetrol 140 and Dis Mist

Yes NA NA 

Co

3 Anaheim Plating 923 E. South St., 

Anaheim

7/16/2008 

JL/JA

>1000 638,302 208,265 Mist Eliminator 

Fumetrol 140 + Dis Mist NP

Yes NA NA 

Co

4 DNR Industries 1562 S. Anaheim Blvd., 

Anaheim

7/16/2008 

JL/JA

>330 242,580 233,058 Fumetrol 140 No - not 

complete

NA Yes, 

portable

Co

5 Hightower Plating 2090 N. Glassen, 

Orange

7/17/2008 

JL/JA

943 1 Million 474,408 Fumetrol 140 

Mist Eliminator HEPA

Yes NA Yes, like 

window sill 

but effective

Se

6 Andres Technical 

Plating

1055 Ortega Way, Placentia

7/17/2008 

JL/JA

865 748,800 82,407 Fumetrol 140 

Mist Eliminator HEPA

No - not 

complete

NA Trays 

present but 

still some 

dripping

Se

7 Orange County 

Plating

940-70 N. Parker St., Orange

7/18/2008 

JL/JA

> 1000 1,150,000 188,488 Clepo Chrome Yes New steel 

splash 

guard, but 

has hole

No, needs drip shield

Se

b

Amp-hr/year ATCM Housekeeping 

1
 Chrome Plating Joint Inspection Results 

Facility Operation and 

Maintenance 

Plan

Inspection and 

Maintenance

Compliance 

Training 

Certification

Source Test 

Conducted

Are Source Test 

Results < 0.0015 

mg/amp-hr?

Is Facility Preparing to 

Comply with ATCM Emission 

Limits? 

Current Complilance Sta

CPPG, Inc Yes Yes Yes May-07 Yes In compliance with emission 

limits

Not in compliance. Chrome spills on walkways. Overspon walls.

Classic Plating Yes Yes 5/29/2008 Oct-02 Source test results 

expressed in mg/dscm. Need to recalculate results.

Facility is waiting for AQMD engineer to recalulate source test results in right units.

Not in compliance. Chrome spills on floor at time of inspection. No barrier to separate buffing from platin

Anaheim Plating Partial Yes 2/29/2008 Mar-93 Results are < 0.0015 

mg/amp-h, but test is too old and only had 2 runs.

At time of joint inspection facility was informed that they will need a new source test. Prior results indicate facility may pass a new source test without any changes.

Not in compliance. Need to hose chrome containment berm at least every seven days instead of monthly. Neadequate barrier between buffing and grinding (currenplywood sheet). Need complete OMP.

DNR Industries Yes NA 2/29/2008 None NA Will need add-on control and 

source test. Owner is getting quotes for HEPA.

Not in compliance. Grinding/buffing in same roas plating. No housekeepinrecords.

Hightower Plating Yes Yes 2/29/2008 Apr-97 Results are < 0.0015 

mg/amp-h, but test is too old.

At time of joint inspection facility was informed that they will need a new source test. Prior results indicate facility may pass a new source test without any changes.

In Compliance 

Andres Technical Plating

No Yes 5/29/2008 Feb-07 Yes In compliance with emission 

limits

Not in compliance. No OM

Spills evident, but NTC alreissued for housekeeping onweek earlier.

Orange County Plating

Not avaiable NA 1/31/2008 None NA Discussed need for add-on 

control, source test and 

possible change of permit limits for more time to comply. Facility is now aware of issues but has not decided on action.

Not in compliance. Need dshield between chrome tanand dragout. Need to patch hole in new splash guard. OMP not available for revie

2
 Chrome Plating Joint Inspection Results 

Facility Location Inspection 

Date

Receptor 

Distance 

(feet)

Control Options 

Used

MRR 

Permitted Actual (2007) Splash 

Guards

Drip Trays Gr

B

B

Amp-hr/year ATCM Housekeeping 

8 Roto-Die 712 N. Valley St., 

Anaheim

7/18/2008 

JL/JA

> 330 3,538,000 Fumetrol 140 

Mist Eliminator HEPA

Yes Yes, small 

splash 

guard 

No, but 

source says 

parts are dry 

before 

transfer to 

rinse tank

Se

9 Bowman Plating 2631 E 126th St. 

Compton

7/15/2008 

EP/WS

75 1.15EE6 980,000 Fumetrol 140 No - not 

complete

Not necessary

NA NA 

10 Cr Ni Plating - 

Bowman Field

2820 E. Martin Luther King Lynwood

7/15/2008 

EP/WS

250 1EE6 725,819 Fumetrol 140 & 

Dist Mist

Yes No Yes Sepa

room 

11 Triumph 2605 Industry Way, 

Lynwood

7/16/2008 

EP/WS

334 20EE6 2.2EE6 Fumetrol 140 & 

HEPA

Yes NA NA NA 

12 A&Z Cr Grinding 1543 Nadeau St. Los 

Angeles

7/16/2008 

EP/WS

100 27,698,286 13.7EE6 HEPA No - not 

complete

Not compliant

NA Not 

Com

13 Aircraft X-ray Labs 2627 E 53rd St. 

Huntington Park

7/17/2008 

EP/WS

88 5EE6 140,000 CMP/HEPA 

Fumetrol 140

No - not 

complete

No but controlled by WWT

No but 

controlled by WWT

NA 

14 Christensen Plating 2455 E 52nd St. 

Vernon

7/17/2008 

EP/WS

800 1.15EE6 17,052 Fumetrol 140 & 

Dist Mist

No - not 

complete

Yes NA Sepa

room barri

3
 Chrome Plating Joint Inspection Results 

Facility Operation and 

Maintenance 

Plan

Inspection and 

Maintenance

Compliance 

Training 

Certification

Source Test 

Conducted

Are Source Test 

Results < 0.0015 

mg/amp-hr?

Is Facility Preparing to 

Comply with ATCM Emission 

Limits? 

Current Complilance Sta

Roto-Die Yes Yes 4/24/2008 Nov-94 Results are < 0.0015 

mg/amp-h, but test is too old.

At time of joint inspection facility was informed that they will need a new source test. Prior results indicate facility may pass a new source test without any changes.

In Compliance

Bowman Plating No - no copy 

onsite

Yes Mar-08 NA NA Source hopes to be able to use 

boric-sulfuric anodize in place of Cr anodize. Depends on customer acceptance

Non-compliant: No copy of OCS report & OMP, No housekeeping records

Cr Ni Plating - Bowman Field

No - no copy onsite

Yes 3/27/2008 NA NA Source plans to get a control 

device

Non-compliant: No copy of OMP

Triumph Yes Yes 3/27/2008 2/10/2004 Yes Yes, largest tank already 

equipped with control device. Source will install one on 2nd tank.

In Compliance 

A&Z Cr Grinding No - no copy 

onsite

Yes 6/6/2007 10/5/2000 Yes Source will try to comply, but 

may be forced out of business

Non-compliant: No barrier between grinding & Tks, No splash guards, No housekeeping records, No O&M onsite

Aircraft X-ray Labs Yes Yes 4/24/2008 1/17/2001 No, result of 0.0018 

mg/amp-hr

Yes - Source already has 2 stage HEPA, but will have to conduct a new source test

Non-compliant: housekeepiform missing wipe cleaningadd drip tray 

Christensen Plating Yes Yes 5/29/2008 NA NA Source may re-permit under 

50,000 amp-hrs to avoid need for control device

Non-compliant: No housekeeping records, no OCS report onsite

4
 Chrome Plating Joint Inspection Results 

Facility Location Inspection 

Date

Receptor 

Distance 

(feet)

Control Options 

Used

MRR 

Permitted Actual (2007) Splash 

Guards

Drip Trays Gr

B

B

Amp-hr/year ATCM Housekeeping 

15 Morrell's 432 E Euclid Compton 7/18/2008 

EP/WS

1044 1.15 EE6 1.121EE6 Fumetrol 140 Yes NA NA NA 

16 Brite Plating 1313 Mirasol, Los 

Angeles

7/18/2008 

EP/WS

>330 1.15EE6 177,000 PBS, Fumetrol 

140 & Dist Mist

No - not 

complete

No NA Yes 

17 Dolphin Engineering 1842 E 41st Place Los 

Angeles

7/22/2008 

EP/WS

1000+ 1.15EE6 17,000 Fumetrol 140 No - not 

complete

NA - no rinsing in Cr tank

NA Yes, 

plastwere open

18 Domar Precision 5250 E. Southern Ave. 

South Gate

7/22/2008 

EP/WS

75 131.4EE6 64,673,147 Scrubber: CMP 

& mist eliminator

No - not 

complete

No NA NA 

19 Coast Plating 417 W 164th St. 

Carson

7/23/2008 

EP/WS

approx. 

200'

1.412EE6 543,000 Fumetrol 140 No - not 

complete

NA Yes NA 

20 Decore Plating 434 W 164th St. 

Carson

7/23/2008 

EP/WS

256 1.15EE6 190K CMP/mist 

elimanator & HEPA

No - not 

complete

Yes Yes NA 

21 Service Plating 1855 E 62nd St. Los 

Angeles

7/24/2008 

EP/WS

106 None 13EE6 PBS/ prefilter 

HEPA

No - not 

complete

No NA Yes 

sepabldgs

5
 Chrome Plating Joint Inspection Results 

Facility Operation and 

Maintenance 

Plan

Inspection and 

Maintenance

Compliance 

Training 

Certification

Source Test 

Conducted

Are Source Test 

Results < 0.0015 

mg/amp-hr?

Is Facility Preparing to 

Comply with ATCM Emission 

Limits? 

Current Complilance Sta

Morrell's Yes Yes 4/21/2008 NA NA Source plans to get a control 

device

In Compliance 

Brite Plating Yes No - lack I&M 

record for scrubber

6/6/2007 7/3/2008 Unknown - don't have 

results yet

Yes Non-compliant: No 

housekeeping records, no Iand Pdrop records for scrubber, need splash guarfor small tank

Dolphin Engineering No - no copy 

onsite

Yes 2/29/2008 NA NA Yes, but source undecided. 

Source may re-permit under 50K amp-hrs 

Non-compliant: No housekeeping records, No O&M plan. 

Domar Precision Yes Yes 3/27/2008 6/6/1995 0.0017 mg/amp-hr but 

must retest

Yes Non-compliant: No 

housekeeping records, No splash guards

Coast Plating NA NA - surface 

tension done by consultant

Yes NA NA Yes, but source undecided - 

source may repermit under 500,000 amp-hrs to buy time

Non-compliant: No copy of OCS report onsite, No housekeeping records

Decore Plating Yes No - lack I&M 

record for CMP/elim HEPA

4/24/2008 7/12/2001 Yes: results of 0.0011 

mg/amp-hr

Yes Non-compliant: No 

housekeeping records, No records for CMP/mist elimanator

Service Plating Yes Yes No certificate 

onsite, 6/6/2009 expiration

No test conducted since '80s

New test must be done Yes Non-compliant: No 

housekeeping record, No 

splash gaurds, No OCS repNeed copy of class certification

6
 Chrome Plating Joint Inspection Results 

Facility Location Inspection 

Date

Receptor 

Distance 

(feet)

Control Options 

Used

MRR 

Permitted Actual (2007) Splash 

Guards

Drip Trays Gr

B

B

Amp-hr/year ATCM Housekeeping 

22 Deluxe Finishing 200 E Slauson, Los 

Angeles

7/24/2008 

EP/WS

105 None 19,810 CMP/mist 

elimanator & HEPA

No - not 

complete

NA - no rinsing in Cr tank

Yes No b

dust contr

23 EME Inc. 431 E Oaks St. 

Compton

7/25/2008 

EP/WS

200 9EE6 225,000 CMP/mist 

elimanator & HEPA

No - not 

complete

NA - no rinsing in Cr tank

NA - tanks fit together tightly

NA 

24 J&D Acquisitions 1366 Spence St. Los 

Angeles

7/25/2008 

EP/WS

358 1.15EE6 638,000 Fumetrol 140 No - not 

complete

One guard out of position

No Yes 

25 Angelus Plating 1713 West 154th, 

Gardena

7/15/2008 

SE/GJ

> 1,000' 1 Million 209,116 Fumetrol 140 & 

Dist Mist

Yes No NA Not 

Com

26 Verne's Plating 1559 West El Segundo, 

Gardena

7/15/2008 

SE/GJ

45' 93 Million 12,000 Fumetrol 140 & 

Dist Mist

Yes Yes NA Sepa

EnclRoom

27 Gardena 

Specialized

16520 South Figueroa, Gardena

7/16/2008 

SE/GJ

200' 1.15 Million 48,651 Fumetrol 140 & 

Polyballs

Yes Rinses 

parts in drums

NA NA 

28 Aerodynamics 13620 South Andrews, 

Gardena

7/16/2008 

SE/GJ

600' 112,800 6,298 Fumetrol 140 & 

Polyballs

Yes No NA NA 

7
 Chrome Plating Joint Inspection Results 

Facility Operation and 

Maintenance 

Plan

Inspection and 

Maintenance

Compliance 

Training 

Certification

Source Test 

Conducted

Are Source Test 

Results < 0.0015 

mg/amp-hr?

Is Facility Preparing to 

Comply with ATCM Emission 

Limits? 

Current Complilance Sta

Deluxe Finishing No - no copy 

onsite

No - lack I&M record for CMP/elim HEPA

5/29/2008 Protocol 

submitted

NA Yes - Source is planning to 

conduct a source test

Non-compliant: No amp-hr no surface tension log, no OCS report, No O&M plan, I&M checklist, No housekeeping record

EME Inc. Yes Yes 2007 10/19/2000 Yes - 0.000008 

mg/amp-hr ARB method 425

Yes In Compliance: Housekeep

form lacked cleaning of spilin an hour and weekly cleaning. New form given tsource.

J&D Acquisitions No - no copy 

onsite

Yes No record NA NA Unknown Non-compliant: No O&M pla

OCS report, need houskeepchecklist, splash guard out position, drag-out tank needto be re-positioned to avoid drips

Angelus Plating Yes Yes 1/29/2008 NA NA No Non-compliant 

Verne's Plating Yes Yes 2/21/2008 NA NA Will submit a new Compliance 

Plan to show ampere-hour usage is <20,000 per year

In Compliance. Needs checklist for weekly clean-u

Gardena Specialized Yes Yes 5/29/2008 NA NA No In Compliance. Needs 

checklist for weekly clean-u

Aerodynamics Yes Yes 5/29/2008 NA NA No Non-Compliant: Air spargin

chrome tank when not in usDripping chromium on floorexceeded surface tension standard on 7/3/2008

8
 Chrome Plating Joint Inspection Results 

Facility Location Inspection 

Date

Receptor 

Distance 

(feet)

Control Options 

Used

MRR 

Permitted Actual (2007) Splash 

Guards

Drip Trays Gr

B

B

Amp-hr/year ATCM Housekeeping 

29 Accuchrome 115 West 154th Street, 

Gardena

7/17/2008 

SE/GJ

350' None 20 Million CMP Prefilter 

HEPA

Yes No NA NA 

30 Coast Plating 128-130 West 134th 

Street, Gardena

7/17/2008 

SE/GJ

350' 1.15 Million 188,390 Fumetrol 140 & 

Water Scrubber

Yes Yes but 

does not drain into tank

NA NA 

31 Chromplate 1127 West Hillcrest 7/18/2008 

SE/GJ

120' 3.2 Million 1,450,020 Fumetrol 140 Yes Tank 1 (no) 

Tank 2 (yes)

Tank 1 (yes) Tank 2 (no)

SepaRoom

32 Multichrome / 

Microplate

1013 West Hillcrest 7/18/2008 

SE/GJ

410' 148 Million 24 Million CMP Prefilter 

HEPA

Yes Yes NA Sepa

Area

33 Supreme 330 East Beech 

Avenue

7/22/08 

SE/GJ

80' 365,000 45,224 Fumetrol 140 No. Surface 

Tension not 

monitored 

7/14 or 7/21

Yes Yes Parti

- not ceilin

34 Southwest 1344 West Slauson 7/22/08 

SE/GJ

90' 365,000 1,574 Fumetrol 140 

Polyballs Water Scrubber

No. Surface 

Tension not 

done weekly

No NA NA 

35 Van Nuys 6109 Vesper Avenue 7/23/2008 

SE/GJ

30' 365,000 3,772 Fumetrol 140 Yes No Plastic 

sheet drapped over tank

Plast

36 Astro Chrome 15236 Erwin 7/23/08 

SE/GJ

<330' None 2,696 Fumetrol 140 

and HEPA

Yes. No July 

Housekeeping 

records

Yes Will install 

drip trays

SepaRoom

37 Crown 14660 Arminta 7/23/08 

SE/GJ

900' 1.15 CR-1:4.3 M 

CR-10: 

10,620

Polyballs and HEPA

Yes C-1: Yes 

CR-10: No

CR-1: Yes CR-10: No

NA 

9
 Chrome Plating Joint Inspection Results 

Facility Operation and 

Maintenance 

Plan

Inspection and 

Maintenance

Compliance 

Training 

Certification

Source Test 

Conducted

Are Source Test 

Results < 0.0015 

mg/amp-hr?

Is Facility Preparing to 

Comply with ATCM Emission 

Limits? 

Current Complilance Sta

Accuchrome Not avaiable Yes 2/21/2008 8/4/2008 Yes - 0.000114 

mg/amp-hr (total Cr); hex-chrome @ 0.0000653 mg/amp-hr

Yes Non-Compliant: Clean 

walkways once per week anrecord; no dripping; install splash guards

Coast Plating Yes Yes 1/29/2008 Never tested Will install a HEPA Non-Compliant: Surface 

tension records for May 200only; no walkway housekeeping records

Chromplate Yes Yes 2/21/2008 NA NA Purchased HEPA CompliantMultichrome / Microplate

Yes Yes 3/28/2008 5/5-6/1999 0.45 MG/Hr Will do a performance test 

before October 24, 2009

Non-Compliant: Keep tank area clean and record

Supreme Yes Yes 5/28/2008 NA NA No Non-Compliant: Keep 

walkways clean and recordInstall barrier to ceiling; chesurface tension weekly and record

Southwest Yes Yes 5/28/2008 3-4 Years Ago Not Available Will submit a new Compliance 

Plan to show ampere-hour usage is <20,000 per year

Non-Compliant: Will do surface tension testing wee

Van Nuys Yes Yes 2/28/2008 Water 

Scrubbers not tested

NA Will submit a new Compliance 

Plan to show ampere-hour usage is <20,000 per year

Non-Compliant: Conduct weekly housekeeping and record; install a drip tray

Astro Chrome Yes Yes 1/31/2008 No. NA Needs to do a performance test Non-Compliant: Install drip 

trays and keep monthly housekeeping records

Crown Yes Yes 1/31/2008 3/12/2002 Yes In compliance with emission 

limits

Compliant

10
 Chrome Plating Joint Inspection Results 

Facility Location Inspection 

Date

Receptor 

Distance 

(feet)

Control Options 

Used

MRR 

Permitted Actual (2007) Splash 

Guards

Drip Trays Gr

B

B

Amp-hr/year ATCM Housekeeping 

38 Moog 20263 South Western 7/24/08 

SE/GJ

>330 29 Million 11 Million Fumetrol 140 

and HEPA

Yes NA T1, T2, T3, 

T4 & 123 need drip trays

NA 

39 Products 

Engineering

2645 Maricopa 7/24/08 

SE/GJ

491' 43 Million 1.7 Million Fumetrol 140, 

Polyballs & MistEliminator

Yes NA Using paper No b

40 Prime Wheel 24000 South Vermont 7/25/08 

SE/GJ

75' 17 Million 12 Million Fumetrol 140 & 

HEPA

Yes NA NA Sepa

Room

41 Maxima 23920 South Vermont 7/25/08 

SE/GJ

<330' 41 Million 31 Million Fumetrol 140 & 

HEPA

Yes NA Chrome 

Drag-Out Tank needs drip tray

SepaRoom

42 Brothers Plating 334 S. Motor, Azusa 8/5/2008 

JL/WS

>1000 365,000 31,778 Fumetrol 140 & 

Dis Mist

Yes Yes No, 

incomplete drip tray

SepaRoom

43 Universal Plating 1526 W. 1st St., Azusa 8/5/2008 

JL/WS

>1000 1,150,000 71,683 Fumetrol 140 & 

Dis Mist

No - not 

complete

Yes Yes NA 

44 Sigma Plating 1040 Otterbein 8/6/2008 

JL/WS

195 70 Million 8 Million 2 HEPAs and 

mist eliminators: 1 set for each line

Yes NA Yes Sepa

Room

45 Size Control 13349 E. Temple Ave., 

La Puente

8/6/2008 

JL/WS

>330 567.5 Million 37.5 Million HEPA & 

Fumetrol 140

Yes NA Use 5 gallon 

bucket to transport parts 

NA 

46 El Monte Plating 11409 Stewart St., El 

Monte

8/7/2008 

JL/WS

Reported > 

1000', but 

house is 

next door

1,150,000 77,166 Benchbrite CR 

1800 / Dis-Mist NP

No - not 

complete

NA No drip tray Barri

apprhigh

11
 Chrome Plating Joint Inspection Results 

Facility Operation and 

Maintenance 

Plan

Inspection and 

Maintenance

Compliance 

Training 

Certification

Source Test 

Conducted

Are Source Test 

Results < 0.0015 

mg/amp-hr?

Is Facility Preparing to 

Comply with ATCM Emission 

Limits? 

Current Complilance Sta

Moog Yes Yes 2/29/2008 8/26-7/02 Yes In compliance with emission 

limits

Non-Compliant: Monitor surface tension for 20 daysinstall drip trays on automatlines; record housekeeping weekly & label ampere-houmeters

Products Engineering

Yes Yes 3/27/2008 12-16-17/99 Yes Will do a performance test 

before October 24, 2009

Non-Compliant: Install drip trays and curtains

Prime Wheel Yes Yes 3/27/2008 9/14/2000 Yes Facility is shutting down Compliant Maxima Yes Yes 3/27/2008 6/18/2007 Yes In compliance with emission 

limits

Non-Compliant: extend drip tray on chrome drag-out tan

Brothers Plating Yes NA 1/31/2008 NA NA Owner plans to source test by 

October 2011 or lower emission limits to < 50,000

Non-Compliant: Install drip trays 

Universal Plating Not needed - 

outsource surface tension

NA 6/6/2007 NA NA Facility is now aware of need 

for add-on control and source test but has not decided how to comply.

Non-compliant: Clean weeand keep housekeeping rec

Sigma Plating Yes Yes 3/27/2008 Hoist line: 

6/22/1998 New Line: 12/18-19/02

Yes Facility is now aware that hoist 

line will need new source test.

Compliant 

Size Control Yes Yes 4/22/2008 12/18-19/2001 Yes In compliance with emission 

limits

Compliant

El Monte Plating Yes for 

stalagmometer

Yes 3/13/2008 NA NA Owner is now aware of 

requirements, but stated they may go out of business (older owner was upset). 

Non-Compliant: need drip tand housekeeping record

12
 Chrome Plating Joint Inspection Results 

Facility Location Inspection 

Date

Receptor 

Distance 

(feet)

Control Options 

Used

MRR 

Permitted Actual (2007) Splash 

Guards

Drip Trays Gr

B

B

Amp-hr/year ATCM Housekeeping 

47 All Fast Fastenings 15200 Don Julian, City 

of Industry

8/7/2008 

JL/WS

> 330 4,632,000 22,525 HEPA & 

Fumetrol 140

Yes NA Portable 

titanium basket

NA 

48 Cytec Engineered 

Materials Inc

1440 N. Kramer Blvd, Anaheim

7/22/2008 

MD/JA

>330 365,000 1,070 Fumetrol 140 

and scrubber

Incomplete NA No drip tray NA 

49 A-H Plating INC/ 

Sunvair Coating Tech

1837 N Victory Blvd, Burbank

7/25/08 

MD/JA

>330 None 2.6 million Polyballs, Mist 

Eliminator & HEPA

Incomplete NTC to 

install splashguards

Yes Sepa

room

50 K & L Anodizing 

Corp

1200 S Victory Blvd., Burbank

7/25/08 

MD/JA

<330 6 million 504,827 Fumetrol 140, 

Mist Eliminator & HEPA

Incomplete NTC to 

install splashguards

Yes NA 

51 Chrometech Inc 2309 W 2nd Street & 

2310 Cape Code Way, Santa Ana

7/24/2008 

MD/JA

>330 None 2,243,061 Fumetrol 140, 

Mist Eliminator & HEPA 

Yes, except 

housekeeping 

record

NA Yes Yes 

separoom sepabuild

52 C&M Gold Plating 948 W. Industrial St., 

Azusa

8/7/2008 

JL/WS

>1000 313,950 11,093 HCA-6.2 No - not 

complete

Incomplete splash guard

Need drip tray

NA 

53 Jan-Kens 715 E. Cypress, 

Monrovia

8/8/2008 

JL/WS

>330 13,140,000 31,247 HEPA, mist 

eliminator & Fumetrol 140

No, need 

weekly housekeeping 

record 

instead of 

quarterly

NA Manager 

said they use a bucket for manual transfer

NA 

13
 Chrome Plating Joint Inspection Results 

Facility Operation and 

Maintenance 

Plan

Inspection and 

Maintenance

Compliance 

Training 

Certification

Source Test 

Conducted

Are Source Test 

Results < 0.0015 

mg/amp-hr?

Is Facility Preparing to 

Comply with ATCM Emission 

Limits? 

Current Complilance Sta

All Fast Fastenings Yes Yes 1/29/2008 12/11/2002 No: 0.0016 mg/amp-hr We discussed need for source 

test to meet 0.0015 mg/amp-hr limit. They will retest and consider additional controls.

Compliant 

Cytec Engineered Materials Inc

Yes Lacking/Issued 

NTC

3/27/08 4/24/08

None conducted

Yes Non-compliant/record surfa

tensions for 20 consecutive days when levels exceededmaintain housekeeping records, calibrate tensionometer

A-H Plating INC/ Sunvair Coating Tech

Yes Yes 6//2008 Yes Yes Non-compliant/NTC to insta

splash guards/maintain rectifier records daily.

K & L Anodizing Corp

Yes Yes 4/24/2008 None 

conducted

Yes NTC - install splash guard 

Chrometech Inc Yes Yes 2/29/2008 16-May No Yes NTC - maintain housekeepi

records to demonstrate compliance with ATCM

C&M Gold Plating Yes for 

stalagmometer

NA 3/27/2008 None 

conducted

NA We discussed need for add-on 

controls and source test to meet limit by Oct. 2011 or to lower permit limit to < 50,000. 

NTC - install complete splaguard and drip tray; keep housekeeping log

Jan-Kens Yes Yes 3/21/2008 4/27-28/1993 Yes, but test is too old. 

(2 runs: 0.00034 and 0.00013)

We discussed the need to retest as existing source test is too old. Prior test indicates facility may pass new test.

Compliant 

14
 Chrome Plating Joint Inspection Results 

Facility Location Inspection 

Date

Receptor 

Distance 

(feet)

Control Options 

Used

MRR 

Permitted Actual (2007) Splash 

Guards

Drip Trays Gr

B

B

Amp-hr/year ATCM Housekeeping 

54 EMBEE INC 2155 South Hathaway, 

Santa Ana

7/24/08 

MD/JA

>330 363 million 91 million Fumetrol 101 

and 140, Polyballs, Mist Eliminator and HEPA 

Incomplete Found in 

need/ Will install

Yes Foun

need prov

55 Markland 

Manufacturing Inc

1111 E McFadden Ave., Santa Ana

7/23/2008 

MD/JA

<330 15,724,000 1,667,533 Fumetrol 140, 

Mist Eliminator and HEPA 

Yes Yes Yes Yes 

56 Omni Metal 

Finishing Inc

11665 Coey River Cir., Fountain Valley

7/23/2008 

MD/JA

>330 1,150,000 25,281 Fumetrol 140 Improvement 

needed

NA Yes Yes 

57 Consolidated 

Foundries - Ponoma

4200 W Valley Blvd, Pomona

8/5/2008 

MD/CR

>330 None 9,420 Fumetrol 140, 

polyballs and PBS 

Improvement 

needed

NA Needed Yes 

58 RMS Finisihing INC 5777 Soestern Court, 

Chino

8/5/08 

MD/CR

>330 No Limit - 

OPEN

1,337,099 Zero Mist, HEPA Improvement 

needed

yes yes yes 

15
 Chrome Plating Joint Inspection Results 

Facility Operation and 

Maintenance 

Plan

Inspection and 

Maintenance

Compliance 

Training 

Certification

Source Test 

Conducted

Are Source Test 

Results < 0.0015 

mg/amp-hr?

Is Facility Preparing to 

Comply with ATCM Emission 

Limits? 

Current Complilance Sta

EMBEE INC Yes Yes 3/27/2008 Partial NA Yes NTC on surface tensions, 

splashguards, buffing/polishbarrier,housekeeping records,etc.

Markland Manufacturing Inc

Not available Yes 2/29/2008 1/28/2005 Yes In compliance with emission 

limits

Non compliant 

Omni Metal Finishing Inc

Yes Yes 3/27/2008 Unknown Unknown - don't have 

results yet

Yes Non compliant 

Consolidated Foundries - Ponoma

Yes Incomplete 2/29/2008 Old-1996 NA Yes Non compliant 

RMS Finisihing INC Not available Yes Not available None none yes Non compliant 

16
 Chrome Plating Joint Inspection Results 

Facility Location Inspection 

Date

Receptor 

Distance 

(feet)

Control Options 

Used

MRR 

Permitted Actual (2007) Splash 

Guards

Drip Trays Gr

B

B

Amp-hr/year ATCM Housekeeping 

59 Kenneth Jeffers 

Chrome Plating

1044 E 2nd St., Ponoma

8/6/08 

MD/CR

<330 53,800 35,251 Dist Mist and 

fumetrol 140

Yes Yes Yes Yes 

60 Hartwell Corp 9810 6th St., Rancho 

Cucamonga

8/6/08 

MD/CR

>330 757,375 126,967 Fumetrol 140, 

polyballs and PBS 

Yes Yes Yes Yes 

61 RTR Industries LLC/ 

Grant Piston Ring Co

1360 Jefferson St., Anaheim

8/7/08 

MD/CR

>330 32,248,944 2,321,158 Polyballs and 

HEPA

Yes Yes Yes NA 

62 Techplate 

Engineering Co

1571 S Sunkist St., Anaheim

8/7/08 

MD/CR

>330 365,000 220,743 Fumetrol 140 & 

Polyballs

Yes Yes Yes Yes 

63 Anodyne INC 2226 S Susan St., 

Santa Ana

8/7/2008 

MD/CR

>330 1,150,000 1,194,745 

(exceeded 

limit)

Fumetrol 140 Incomplete Need Need Yes 

64 Fontana Polishing 

and Plating

130 W Mindanao, Bloomington

8/8/08 

MD/CR

>330 3,120,000 29,399 Fumetrol 140, 

Dist Mist & HEPA 

Incomplete Yes Yes Yes 

65 Carter Plating Inc. 1842 Keystone, 

Burbank

8/13/2008 

JF/JA

>330 

(>1000+)

500,000 51,488 Fumetrol 140 

and DisMist NP

Yes NA NA Outs

build

66 Technical Metal 

Finishing

3401 Pacific Ave. Burbank

8/13/2008 

JF/JA

302' 365,000 54,814 Fumetrol 140 Yes No No NA 

67 Pemaco Metal 

Processing

2125 Lemon St. Alhambra

8/14/2008 

JF/JA

>330 

(>1000)

1.15EE6 395,418 Zero Mist liquid 

R 

Yes NA Yes Outs

separoom

68 Cal-Tron Processing 11919 Rivera Rd. 

Santa Fe Springs

8/13/2008 

HJ/WS

>330 1.15EE6 0.5EE6 Polyballs and 

Fumetrol

Yes Yes Yes NA 

69 Whiting Enterprises 10140 Romandel Ave. 

Santa Fe Springs

8/13/2008 

HJ/WS

>330 70EE6 0.77EE6 Fumetrol 140 & 

CMP mist elim & HEPA

Yes Yes Yes NA 

17
 Chrome Plating Joint Inspection Results 

Facility Operation and 

Maintenance 

Plan

Inspection and 

Maintenance

Compliance 

Training 

Certification

Source Test 

Conducted

Are Source Test 

Results < 0.0015 

mg/amp-hr?

Is Facility Preparing to 

Comply with ATCM Emission 

Limits? 

Current Complilance Sta

Kenneth Jeffers Chrome Plating

Yes Yes 3/27/2008 None none Yes Non compliant 

Hartwell Corp Yes Yes 4/24/2008 None (old) None Yes Non compliant 

RTR Industries LLC/ Grant Piston Ring Co

Yes Yes 6/6/2007 None (old) None Yes Compliant 

Techplate Engineering Co

Yes Yes 6/6/2007 None None Yes Compliant 

Anodyne INC Yes Lacking/Issued 

NTC

2/29/2008 None None Yes Non compliant 

Fontana Polishing and Plating

Yes Yes 5/29/2008 None None Yes Non compliant 

Carter Plating Inc. Yes Yes Yes None NA Source will do what is needed 

to comply with 10/24/11 limits and will talk to consultant

Non-compliant: Need housekeeping records

Technical Metal Finishing

Yes Yes Yes NA NA Source will talk to consultant, 

must comply w/ .0015 by 10/24/09

Non-compliant: Need housekeeping records

Pemaco Metal Processing

Yes Yes Yes NA NA May lower permit limit, but 

cannot afford HEPA

Non-compliant: Need housekeeping records

Cal-Tron Processing Yes Yes Yes NA NA Source has received quote for 

hood and HEPA filter. Have not received A/C yet

In compliance 

Whiting Enterprises Yes Yes Yes Jun-04 Yes - 0.000826 

mg/amp-hr 

Source is in compliance with new limits effective 10/24/2009

In compliance 

18
 Chrome Plating Joint Inspection Results 

Facility Location Inspection 

Date

Receptor 

Distance 

(feet)

Control Options 

Used

MRR 

Permitted Actual (2007) Splash 

Guards

Drip Trays Gr

B

B

Amp-hr/year ATCM Housekeeping 

70 Rebilt Metalizing 

Co.

2229 E 38th St. Vernon 8/14/2008 

HJ/WS

>330 77EE6 123,000 Polyballs w/ 

HEPA

Yes Drips 

contained 

sent to tank 

NA NA 

71 Bronzeway Plating 3432 E15th St. Los 

Angeles 

8/14/2008 

HJ/WS

>330 1.15EE6 49,200 Polyballs & HCA4 Yes Yes Yes Sepa

room 

19
 Chrome Plating Joint Inspection Results 

Facility Operation and 

Maintenance 

Plan

Inspection and 

Maintenance

Compliance 

Training 

Certification

Source Test 

Conducted

Are Source Test 

Results < 0.0015 

mg/amp-hr?

Is Facility Preparing to 

Comply with ATCM Emission 

Limits? 

Current Complilance Sta

Rebilt Metalizing Co. Yes Yes Yes Nov-99 Yes - 0.000105 

mg/amp-hr

Source will have to conduct a new source test by 10/09

In compliance 

Bronzeway Plating Yes Yes Yes NA NA Unknown - Source advised of 

upcoming timelines with 10/2009 deadline

In compliance 

20
Attachment C 

Housekeeping Photographs 
General Housekeeping 

Poor housekeeping: Drips of chrome solution on walkway 

Example of good housekeeping 
Drip Tray to Minimize Dragout 

A proper drip tray between a chrome tank and drag 

out tank 

Lack of a drip tray between tanks 
Splash Guard to Minimize Overspray 

Operation with proper splash guards 

Stains showing overspray due to 

lack of splash guard 
Physical Barrier between Buffing/Grinding and Plating Operations 

A proper barrier consisting of plastic strips 

Absence of a physical barrier