ENGINEERING EVALUATION REPORT

PLANT NAME Industrial Plating

APPLICATION NUMBER 1911 6

PLANT NUMBER 3873

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

2 2843 24179 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. The ATCM allows

facilities to operate at throughputs up to 50,000 amp

- hr/yr using only a surfactant, if the facility is

located more than 330 feet from the nearest sensitive receptor. This facility wa s previously

conditioned to a throughput of 1 50,000 amp

- hr/hr, but has accepted a revised condition limit of

50,000 amp

- hr

.

Basis Throughput, a

- hr/yr Factor, mg/a

- hr Emissions, lb/yr

Current 1 50,000 0.01 0.00 33

Post

- ATCM 50,000 0.01 0.0011

Net Differen ce 0 0 0 .0022AN 19116/Industrial Plating (Plant A3873)

RE Frazier, P.E.

11/13/2008

2 3. CEQA

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 app licable.

5. EXEMPTIONS

There are no applicable exemptions.

6

. OFFSETS

Offsets are not applicable, since emissions do not increase , therefore no offset triggers are

exceeded.

7

. TOXIC EVALUATION

Emission levels decrease , therefore no toxic evaluati on is required. Previous toxic risk

evaluations have been conducted showing there 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 the ri sk was not found to be significant when the emissions were 0.0033

lb/yr, we do not expect any increased risk at 0.0011 lb/yr.

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 version of Condition 2843 is presented in this application, as is the new Template

Condition 24179

. Condition 24179 is written in general terms for any facility located more than

330 feet f rom any sensitive receptor, with permitted throughput of less than or equal to 50,000

amp

- hr/yr.

10. RECOMMENDATIONS

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

Condition 24179

.

OLD CONDITION 2843

COND# 2843

--------------------------------------AN 19116/Industrial Plating (Plant A3873)

RE Frazier, P.E.

11/13/2008

3 1. Throughput

The total annual combined throughput at source S

- 2

shall not exceed 150,000 amp

- hrs in any consecutive

twelve month period.

2. Amp

- hours of operation

To comply with the above condition, Industrial

Plating 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 wit hout the simultaneous operation of the

ampere

- hour meter.

3. Abatement

- Plating Bath Surface Tension

Source S

- 2 shall not be operated unless the plating

bath is operated with A totech CMS Fume Suppressant

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 conditio n 3, above,

surface tension of source S

- 2 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 su rface 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 fre quency 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 shall b e 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 beenAN 19116/Industrial Plating (Plant A3873)

RE Frazier, P.E.

11/13/2008

4 appropriately validated us ing EPA Method 301,

Appendix A, 40 CFR Part 63.

6. Initial Performance Testing

- Required Records

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. Re cordkeeping

Industrial Plating shall keep and maintain the

following records associated with source S

- 2:

a. Performance test records.

b. Operating throughput records (mont hly, amp

- hour throughput)

c. Records of chemical additions to chrome

plating bath.

8. Reporting

Industrial Plating shall provi de 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 throughput of chrome plating

operation in ampere

- hours: Submit on an

annual basis as requested through the BAAQMD

annual update program.

9. Retention of R ecords

Industrial Plating 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 COND ITION 24179

COND# 24179

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

The owner/operator shall comply with the following

Conditions for the hexavalent chrome plating source(s).

Basis refers to either BAAQMD Regulations/Rules or

Californi a Code of Regulations, Title 17, Section 93102

-AN 19116/Industrial Plating (Plant A3873)

RE Frazier, P.E.

11/13/2008

5 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 shall not

exceed 50,000 ampere

- hours in any consecutive 12

- month

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

2. Abatement

Surface Tension: The owner or operator shall 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 specific to the

chosen suppressant additive and surface tension test

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

Suppressant Name Stalagmometer Tensiometer

(M anufacturer) (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 onsit e and has completed the ARB

Compliance Assistance Training Course pertaining to

chrome plating and chrome anodizing.

[Basis: 93102.5(b)]

4. Housekeeping

The following housekeeping requirements shall be

implemented to reduce potential hexavalent chrome

fugitive emissions: [Basis: 93102.5(c)]

a) Chromic acid materials shall be stored in a c losed

container in an enclosed storage area.AN 19116/Industrial Plating (Plant A3873)

RE Frazier, P.E.

11/13/2008

6 b) Chromic acid materials shall be transported from

storage to the bath in a closed container.

c) Any liquid or sold hexavalent chrome contai ning

material that is spilled shall be contained or

cleaned up within one hour after being spilled.

d) Dragout shall be minimized by:

i. handling the plated parts so that chromi c 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, shall be cleaned at least

one time every seven days by either HEPA vacuuming,

damp cloth hand wiping, wet mopping, use of non

- toxic dust suppressants or any other District

- approved method.

f) Buffing, grinding or polishing areas shall be

sepa rated 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 non

- resettable meter which records ampere

- hours

continuously during rectifier operation. Each

ampere

- hour meter shall be installed and maintained

per manufactu rer'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 days. 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 weeklyAN 19116/Industrial Plating (Plant A3873)

RE Frazier, P.E.

11/13/2008

7 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) Plan

The owner/operator shall prepare an operation and

maintenance plan for the chrome plating operation,

which shall be retained onsite and made available for

inspection upo n 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) Inspecti on 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 devic es 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

recti fier ampere

- hour totals.

c) Breakdown Records noting the occurrence,

duration, cause (if known), and action taken.AN 19116/Industrial Plating (Plant A3873)

RE Frazier, P.E.

11/13/2008

8 d) Records of excesses of the ampere

- hour

limitations of Part 1 or the su rface tension

limits of Part 2.

e) Housekeeping Records demonstrating compliance

with Part 4, above, including date and time of

housekeeping activity.

8) Reporting

The owner or operator shall submit an annual compliance

status report to the District [Compliance & Enforcement

Division] on or before February 1, and sha ll 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 chrome 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

parameters

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

controls sinc e 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 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 C ompliance Training

Program.

Name: Name:

Title: Title:AN 19116/Industrial Plating (Plant A3873)

RE Frazier, P.E.

11/13/2008

9 Name:

Title:

Report Certified by:

Title:

Date:

list condition NUMB ER >>