ENGINEERING EVALUATION REPORT

PLANT NAME Gold Seal Plating

APPLICATION NUMBER 19122

PLANT NUMBER B4817

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

It should be noted that this source is a trivalent chrome plating tank, therefore many of the 

requirements that specifically deal with emission limits are not applicable to these platers.

Source Old Cond New Cond Bath Control Abatement-1 Abatement-2

1 20257 20257 Any Listed 

Surfactant

In Section

93102.8(a)

n/a n/a

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

Emission calculations are not presented in this application. No emission factors are available for 

trivalent chrome. Also, there are no health standards (health threshold levels) established for 

trivalent chrome.

3. CEQA
AN 19122/Gold Seal Plating (Plant B4817)

RE Frazier, P.E.

11/13/2008

2

Since there is no increase in the permitted emission levels, this application is exempt from CEQA 

review per Reg 2-1-312.1.

4. BEST AVAILABLE CONTROL TECHNOLOGY

There is no increase in emission levels, therefore BACT is not applicable.

5. EXEMPTIONS

There are no applicable exemptions.

6. OFFSETS

Offsets are not applicable since emissions are not expected to increase.

7. TOXIC EVALUATION

There is no toxic risk values associated with trivalent chrome, therefore a toxic evaluation is not 

appropriate.

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 Condition 20257 is presented in this application, as is the new Template Condition 

20257. Condition 20257 is written in general terms for any trivalent chrome plating facility.

10. RECOMMENDATIONS

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

Condition 20257.

OLD CONDITION 20257

 COND# 20257 --------------------------------------

 1. Wetting Agent Additive: This trivalent chrome

 plating bath shall not be operated unless at least

 one of the bath components contains a wetting agent

 additive. [Basis: Reg 11 Rule 8, Section (c)(3)] 

 2. Recordkeeping: The owner/operator shall maintain

 records of the bath components purchased with the

 wetting agent clearly identified as a bath

 constituent contained in one of the components.
AN 19122/Gold Seal Plating (Plant B4817)

RE Frazier, P.E.

11/13/2008

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 [Basis: Reg 11 Rule 8, Section (h)(9), Reg 1-441] 

 3. Reports: Within 30 days of issuance of this permit

 the owner/operator shall submit a notification

 of compliance status that contains:

 [Basis: Reg 11 Rule 8, Section (i)(5)] 

 a. A statement that a trivalent chromium process

 that incorporates a wetting agent will be used

 to comply with Parts 1 & 2, above. 

 b. The list of bath components that comprise the

 trivalent chromium bath, with the wetting agent

 clearly identified.

NEW CONDITION 20257

 COND# 20257 --------------------------------------

 1. Emission Controls: 

 The owner or operator shall control emissions from the

 trivalent chrome plating bath by the use of a chemical

 fume suppressant containing a wetting agent.

 [Basis: H&S Code 93102.6(a)(1)] 

 2. Ampere-hour monitoring: 

 Each trivalent chrome electroplating tank, or group of

 tanks, shall install and maintain (per manufacturer's

 instructions) a continuous recording, non-resettable

 ampere-hour meter that operates on the electrical power

 lines connected to the tank or group of tanks. A

 separate meter shall be hard-wired for each rectifier.

 [Basis: H&S Code 93102.9(a)] 

 3. Recordkeeping: 

 Ampere-hours: The owner or operator shall maintain

 monthly records of total ampere-hour throughput, for

 each trivalent chrome plating tank.

 [Basis: H&S Code 93102.9(a)] 

 Bath Additives: In order to demonstrate compliance

 with part 1, above, the owner or operator shall

 maintain records of bath components purchased, with the

 wetting agent clearly identified as a bath constituent

 contained in one of the components. [Basis: H&S Code

 93102.13(e)] 

 4. Reporting 

 The owner or operator shall report the annual

 throughput for each trivalent chrome plating tank in
AN 19122/Gold Seal Plating (Plant B4817)

RE Frazier, P.E.

11/13/2008

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 ampere-hours as directed by the BAAQMD in the annual

 update permit renewal program. [Basis: Regulation 1-

 441]