ENGINEERING EVALUATION REPORT

PLANT NAME DOE

- KAO Sandia Labs

APPLICATION NUMBER 19112

PLANT NUMBER 290

DATE 11

- 13

- 2008

1. BACKGROUND

On October 24, 2007, a major revision to the Airborne Toxic Control Measure (ATCM) for

Chromium Plating and Chro mic 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 sourc es

involved and the current and revised condition numbers. The ATCM can be found at the following

website: http://www.arb.ca.gov/toxics/atcm/chroatcm.pdf

Source Old Cond New Cond Bath Contr ol Abatement

- 1 Abatement

- 2

77 5952 5952 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 r eviewed 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 me asurement 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

This facility is located mo re than 330 feet from the nearest sensitive receptor. Also the chrome

plating tank is permitted to operate up to 46,000 amp

- hr/yr. The ATCM allows facilities to operate

at throughputs up to 50,000 amp

- hr/yr using only a surfactant, if the facility is loc ated more than

330 feet from the nearest sensitive receptor. Th e permitted throughput level will not be increased

though, since that would constitute an emission increase in this case. Therefore, we do not

expect any change in the emission levels.

Basis Throughput, a

- hr/yr Factor, mg/a

- hr Emissions, lb/yr

Current 46,000 0.01 0.00101

Post

- ATCM 46,000 0.01 0.00101AN 19112 /DOE

- Sandia (Plant A290 )

RE Frazier, P.E.

11 /13/2008

2 Net Difference 0 0 0

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

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

5. EXEMPTIONS

There are no applicable exemptions.

6

. OFFSETS

Offsets are not applicable, si nce emissions remain the same , therefore no offset triggers are

exceeded.

7

. TOXIC EVALUATION

Permitted emission levels remain static , therefore no toxic evaluation is required. Previous toxic

risk evaluations have been conducted showing there are no s ignificant risks to any member of the

public from these operations. A previous risk evaluation showed risks to the MEI were less than

10 in a million. Since there is no change in emissions, we do not expect risk levels to change.

8

. STATEMENT OF COMPLI ANCE

The purpose of revising the permit conditions is to ensure that the facility complies with the newly

revised air toxic control measure.

9. CONDITIONS

The previous version of Condition 5952 is presented in this application, as is the revised Condit ion

5952

.

10. RECOMMENDATIONS

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

Condition 5952

.

OLD CONDITION 5952

COND# 5952

--------------------------------------

1) ThroughputAN 19112 /DOE

- Sandia (Plant A290 )

RE Frazier, P.E.

11 /13/2008

3 The total annual combined throughput at source S

- 77 shall

not exceed 46,000 amp

- hrs in any consecutive twelve month

period.

2) Amp

- hours of operation

To comply with the above condition, DOE

- Sandia

Laboratories shall keep and maintain monthly records of

current applied to this source integrated over time, in

units of ampe re

- hours. Ampere

- hour records to be

monitored using non

- resettable amp

- hour meter. Ampere

- hour meter to be installed in a manner so as to prevent

the operation of the bath rectifier without the

simultan eous operation of the ampere

- hour meter.

3) Abatement

- Plating Bath Surface Tension

Source S

- 77 shall not be operated unless the plating bath

is operated with a wetting

- agent additive with bath

surface tension not to exceed 45 dyne/cm.

4) Monitoring of Surface Tension

- Frequency

To demonstrate compliance with condition 3, above,

surface tension of source S

- 77 shall be monitored at a

frequency of at least one time every 4,000 amp

- hours of

bath operation.

If after 40,000 amp

- hours of rectifier operation, the

surface tension monitoring results indica te no

exceedances of the maximum surface tension standard

identified in Condition 3, above, the monitoring

frequency can be reduced to "at least one time every

8,000 amp

- hours of bath operation."

If further surface tension monitoring results indicate no

exceedances of the maximum surface tension standard

identified in Condition 3, above, after an additional

40,000 amp

- hours of operation, t he monitoring frequency

can be further reduced to "at least one time every 40,000

amp

- hours of bath operation".

5) Surface Tension Monitoring

- Testing Methods

Surface tension testing s hall be conducted as specified

in EPA Method 306

- B by the use of a stalagmometer or

preciser tensiometer as directed by manufacturers

instructions. Alternate test methods may also be used if

the method has be en appropriately validated using EPA

Method 301, Appendix A, 40 CFR Part 63.

6) Initial Performance Testing

- Required Records

In the process of conducting the initial performanceAN 19112 /DOE

- Sandia (Plant A290 )

RE Frazier, P.E.

11 /13/2008

4 testing, t he following records shall be kept:

a) Sampling and analysis procedures.

b) Raw data sheets.

c) Documentation of calculations.

d) Source testing results.

7) Recordkeeping

DOE

- Sandia Laboratories shall keep and maintain the

following records associated with source S

- 77:

a) Performance test records.

b) Operating throughput records (mo nthly, amp

- hour

throughput)

c) Records of chemical additions to chrome plating bath.

8) Reporting

DOE

- Sandia Laboratories shall provide the BAAQMD with the

following reports at the specified frequencies identified

as follows:

a) Notification of initial compliance status: Within 90

days of compliance performance test.

b) Annual total thr oughput of chrome plating operation in

ampere

- hours: Submit on an annual basis as requested

through the BAAQMD annual update program.

9) Retention of Records

DOE

- Sandia Laboratories shall retain copies of all of the

above required records and reports associated with the

decorative chrome plating operation for a period of at

least five years.

NEW CONDITION 5952

COND# 5952

------------- -------------------------

The owner/operator shall comply with the following

Conditions for hexavalent chrome plating source S

- 77.

Basis refers to either BAAQMD Regulations/Rules or

California Code of Regulations, Title 17, Section 931 02

- 93102.16 and associated appendices, unless otherwise noted.

Web address: http://www.arb.ca.gov/toxics/atcm/chroatcm.pdf

1. Performance Standards

Throughput: The total annual throughput sha ll not

exceed 46,000 ampere

- hours in any consecutive 12

- month

period. [Basis: 93102.4(b)(1)]

2. AbatementAN 19112 /DOE

- Sandia (Plant A290 )

RE Frazier, P.E.

11 /13/2008

5 Surface Tension: The owner or operator sh all control

hexavalent chrome emissions by the use of one of the

following CARB

- approved chemical fume suppressants,

with the plating bath surface tension not to exceed the

following values in dynes/centimeter specif ic to the

chosen suppressant additive and surface tension test

method. [Basis: 93102.8(a)&(b)]

Suppressant Name Stalagmometer Tensiometer

(Manufacturer) (dynes/cm) (dynes /cm)

Benchbrite CR 1800 <40 <35

(Benchmark Products)

Clepo Chrome <40 <35

(MacDermid)

Fumetrol 140 <40 <35

(Atotech U.S.A.)

HCA

- 6.2 <32 <28

HCA

- 4 <32 <28

(Hunter C hemical LLC)

3. Training

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

calendar years thereafter, the owner or operator shall

ensur e 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

Compli ance Assistance Training Course pertaining to

chrome plating and chrome anodizing.

[Basis: 93102.5(b)]

4. Housekeeping

The following houseke eping requirements shall be

implemented to reduce potential hexavalent chrome

fugitive emissions: [Basis: 93102.5(c)]

a) Chromic acid materials shall be stored in a closed

container in an enclosed storage area.

b) Chromic acid materials shall be transported from

storage to the bath in a closed container.

c) Any liquid or sold hexavalent chrome containing

material that is spilled s hall be contained or

cleaned up within one hour after being spilled.

d) Dragout shall be minimized by:AN 19112 /DOE

- Sandia (Plant A290 )

RE Frazier, P.E.

11 /13/2008

6 i. handling the plated parts so that chromic acid

is not dripped out side the tank, and

ii. installing splash guards at the tank to

minimize overspray and to ensure that chrome

solution is returned to the tank.

e) Surfaces within the chrome storage area and the

walkways and other areas potentially contaminated

with hexavalent chrome, shall be cleaned at least

one time every seven days by either HEPA vacuuming,

damp cloth hand wiping, wet mopping, us e of non

- toxic dust suppressants or any other District

- approved method.

f) Buffing, grinding or polishing areas shall be

separated from the chrome plating operation by a

physical barrier, which may include, but is not

limited to vertical plastic strip curtains.

g) Chromium containing wastes generated as a result of

any of the above housekeeping activities shall be

stored, disposed of, recovered, or recycled using

practices that minimize fugitive dust.

5. Monitoring

a) Each rectifier shall be hard

- wired to a single n on

- resettable meter which records ampere

- hours

continuously during rectifier operation. Each

ampere

- hour meter shall be installed and maintained

per manufacturer's specifications. The

owne r/operator shall record the total ampere

- hours

used during each month.

[Basis: 93102.9(a), 93102.12(c)(1)]

b) Surface Tension monitoring: In order to

demonstrate compliance with part 2, abo ve, the

surface tension shall be initially measured and

recorded daily for 20 operating days. If there are

no exceedance of the surface tension standard during

the initial 20 operating day tests, the mea surement

frequency may be automatically extended to one time

per calendar week of plating tank operation. If an

exceedance occurs, the measurement frequency shall

return to daily for 20 operating days, a nd weekly

thereafter. [Basis: 93102.9(d), 93102.12(c)(4)]

Surface Tension Testing Methods: If using a

Tensiometer, test method shall be EPA Method 306B.

If using a Stalagmometer, test method is noted in

Section 93102 Appendix 8, or as per written

manufacturer instructions, or in any other District

- approved procedure. [Basis: 93102.7(c)(3)]

6. Operation & Maintenance (O&M) PlanAN 19112 /DOE

- Sandia (Plant A290 )

RE Frazier, P.E.

11 /13/2008

7 The owner/operator shall prepare an operation and

maintenance plan for the chrome plating operation,

which shall be retained onsite and made available for

inspection upon request. Any revisions to the O & M

Plan shall be documented in an addendum and all

versions shall be maintained for a period of 5 years

after each revision to the plan. The O&M Plan shall at

a minimum include:

a) The inspection and maintenance requirements for the

chrome plating bath, amp

- hr meter(s)/totalizers,

stalagmometer or tensiometer. [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]

7. Recordkeeping

The owner/operator shall maintain the following records

for at least five years, with the most recent two years

maintained onsite.

a) Inspection Records to demonstrate that such

inspections were done in accordance with the

provisions of Section 93102.10 and the O&M Plan.

Such records can take the form of a checklist and

shall identify the devices inspected, the date and

time of the inspection, a brief description of the

working condition and any corrective actions.

b) The owner/operator shall:

[Basis: 93102.12]

i. Record the platin g bath surface tension

according to the testing frequencies noted

in Part 5.b), and

ii. Record monthly and cumulative 12

- month

rectifier ampere

- hour totals.

c) Breakdown Records noting the occurrence,

duration, cause (if known), and action taken.

d) Records of excesses of the ampere

- hour

limitations of Part 1 or the surface tension

limits of Part 2.

e) Housekeeping Records demonstrating compliance

with Part 4, above, including date and time of

housekeeping activity.

8) ReportingAN 19112 /DOE

- Sandia (Plant A290 )

RE Frazier, P.E.

11 /13/2008

8 The owner or operator shall submit an annual compliance

status report to the District [Compliance & Enforcement

Division] on or before February 1, and shall include the

following informatio n for the preceding calendar year.

1. Company Information

a.Facility Name & Plant Number:

b.Facility Address:

c.Facility Phone Number:

d.Name of Owner or Operator

e.Distance from chrome source to nearest receptor:

2. Relevant Requirements:

a.Maximum Ampere

- Hour Limit:

b.Surface Tension Limit to stay below:

c.Mist Suppressant Additive Used:

3. Actual cumulative ampere

- hour usage on a m onth by

month basis, for the calendar year reporting period.

4. Actual annual hexavalent chrome emissions (lb/yr):

Annual emissions = actual ampere

- hours multiplied by

0.02203, then divided by 1,000,000 = hex ch rome

emissions in lb/yr

5. Summary of any excess emissions/exceeded monitoring

parameters

6. Were there any changes in monitoring, processes, or

controls since the last reporting period? Yes No

(circle the appropriate choice)

If yes, provide a description of the changes.

Certifications:

1) I (name and title) certify that the

inspection and maintenance requirements identified in the

Operation and Maintenance Plan were or were not followed

(circle the appropriate choice). If the requirements were

not followed, provide an explanation, with a copy of the

report required by P art 6(a) of this Condition.

2) I (name and title) certify that the

following individuals have within the past 2 calendar years,

completed a CARB

- approved Environmental Compliance Training

Program.

Name: Name:

Title: Title:

Name:

Title:

Report Certified by:

Title:

Date: