001.1_ ENGINEERING EVALUATION REPORT

PLANT NAME High Lustre Metal Finishing

APPLICATION NUMBER 19119

PLANT NUMBER 7111

DATE 11

- 13

- 2008

1. BACKGROUND

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

Chromium Plating and Chromic Acid Anodizing became law in California. As a result, the permit

conditions for the District chrome platers (there are no chromic acid anodizers operating in the

BAAQMD) need to be revised to address these changes. Following is a listing of the sources

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

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

Source Old Cond New Cond B ath Control Abatement

- 1 Abatement

- 2

1 6595 6595 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:** Excep t 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 whi ch 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 device s 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

This facility is lo cated more than 330 feet from the nearest sensitive receptor. Also the chrome

plating tank is currently permitted to operate up to 45

, 5 00 amp

- hr/yr. The ATCM allows facilities

to operate at throughputs up to 50,000 am p

- hr/yr using only a surfactant, if t he facility is located

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 emiss ion levels.

Basis Throughput, a

- hr/yr Factor, mg/a

- hr Emissions, lb/yr

Current 45

, 5 00 0.01 0.001

Post

- ATCM 45,5 00 0.01 0.001AN 19119/High Lustre (Plant A7111)

RE Frazier, P.E.

11/13/2008

2 Net Difference 0 0 0

3. CEQA

Since the change of conditions will result in no change 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 a pplicable, since 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 t here are no significant 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

. STATEM ENT OF COMPLIANCE

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

revised air toxic control measure.

9. CONDITIONS

The previous version of Condition 6595 is presented in this application, as is the r evised Condition

6595

.

10. RECOMMENDATIONS

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

Condition 6595

.

OLD CONDITION 6595

COND# 6595

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

1) Throughp utAN 19119/High Lustre (Plant A7111)

RE Frazier, P.E.

11/13/2008

3 The total annual combined throughput at source S

- 1 shall

not exceed 45,500 amp

- hrs in any consecutive twelve month

period.

2) Amp

- hours of operation

To comply with the above condition, High Luster Metal

Finishing shall keep and maintain monthly records of

current applied to this source integrated over time, in

units of ampere

- 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 witho ut the

simultaneous operation of the ampere

- hour meter.

3) Abatement

- Plating Bath Surface Tension

Source S

- 1 shall not be operated unless the plating bath

is operated with McGean Rohco Dis

- mist FCS

- 1 wetting

- agent additive or equivalent 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

- 1 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 indicate 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, the monitoring frequency

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

amp

- hours of bath operation".

5) Su rface Tension Monitoring

- Testing Methods

Surface tension testing shall 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 been appropriately validated using EPA

Method 301, Appendix A, 40 CFR Part 63.

6) Initial Performance Testing

- Required RecordsAN 19119/High Lustre (Plant A7111)

RE Frazier, P.E.

11/13/2008

4 In the process of conducting the initial performance

testing, the following records shall be kept:

a) Sampling and analysis procedures.

b) Raw data sheets.

c) Documentation of calculations.

d) Source testing results.

7) Recordkeeping

High Luster Metal Finishing shall keep and maintain the

following records associated with source S

- 1:

a) Performance test records.

b) Operating throughput records (monthly, amp

- hour

throughput)

c) Records of chemical additions to chrome plating bath.

8) Reporting

High Luster Metal Finishing shall provide the BAAQMD with

the following reports at the specified frequencies

identified as follows:

a) Notification of initial compliance stat us: Within 90

days of compliance performance test.

b) Annual total throughput of chrome plating operation in

ampere

- hours: Submit on an annual basis as requested

through the BAAQMD annual update program.

9) Retention of Records

High Luster Metal Finishing 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 6595

COND# 6595

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

The owner/operator shall comply with the following

Conditions for Source 1 Chrome Plating Tank. Basis refers

To either BAAQMD Regulations/Rules or California Code of

Regulations, Title 17, Section 93102

- 93102.16 and

Associated appendices, unless otherwise noted.

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

1. Performance S tandards

Throughput: The total annual hexavalent chrome plating

throughput shall not exceed 45,500 ampere

- hours in any

consecutive 12

- month period.

[Basis: 93102.4(b)(1)]AN 19119/High Lustre (Plant A7111)

RE Frazier, P.E.

11/13/2008

5 2. Abatement

Surface Tension: The owner or operator shall control

hexavalent chrome emissions by the use of one of the

following CARB

- approved chemic al fume suppressants,

with the plating bath surface tension not to exceed the

following values in dynes/centimeter specific 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 Chemical LLC)

3. Training

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

calendar years thereafter, the owner or operator shall

ensure that hexavalent chrome based plating operations

(including environmental compliance/recordkeeping) are

under the direction of the owner or operator or current

employee who is onsite and has completed the ARB

Compliance Assistance Training Course pertaining to

chrome plating and chrome anodizing.

[Basis: 931 02.5(b)]

4. Housekeeping

The following housekeeping requirements shall be

implemented to reduce potential hexavalent chrome

fugitive emission s: [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 t he 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.AN 19119/High Lustre (Plant A7111)

RE Frazier, P.E.

11/13/2008

6 d) Dragout shall b e minimized by:

i. handling the plated parts so that chromic acid

is not dripped outside 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, sh all 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.

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 curtai ns.

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 non

- resettable meter which records ampere

- hours

continuously during rectifier operation. Each

ampere

- hour meter shall be installed and maintained

per manufacturer's specifications. The

owner/operator shall record the total ampere

- hours

used during each month.

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

b) Surface Tension monitoring: In order to

demonstrate compliance with part 2, above, the

surface tension shall be initially measured and

recorded daily for 20 operating d ays. If there are

no exceedance of the surface tension standard during

the initial 20 operating day tests, the measurement

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, and weekly

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

Surface Tension Testing Me thods: 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 othe r District

- approved procedure. [Basis: 93102.7(c)(3)]AN 19119/High Lustre (Plant A7111)

RE Frazier, P.E.

11/13/2008

7 6. Operation & Maintenance (O&M) Plan

The owner/operator shall prepare an operation and

maintenance plan for the chrome plating op eration,

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)/totalize rs,

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 operatin g

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 plating 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 Pa rt 4, above, including date and time of

housekeeping activity.AN 19119/High Lustre (Plant A7111)

RE Frazier, P.E.

11/13/2008

8 8) Reporting

The owner or operator shall submit an annual compliance

status rep ort to the District [Compliance & Enforcement

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

following information 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 month by

month basis, for the calendar year reporting period.

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

Annual emissions = actual ampere

- hours multiplied by

0.02203, then divided by 1,000,000 = hex chrome

emissions in lb/yr

5. Summary of any excess emissions/exceeded monitoring

par ameters

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.

Cert ifications:

1) I (name and title) certify that the

inspection and maintenance requirements identified in the

Operation and Maintenance Plan were or were not followed

(circ le the appropriate choice). If the requirements were

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

report required by Part 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:AN 19119/High Lustre (Plant A7111)

RE Frazier, P.E.

11/13/2008

9 Date: