ENGINEERING EVALUATION REPORT

PLANT NAME Western Roto Engravers/ColorTech

APPLICATION NUMBER 19197

PLANT NUMBER A4538

DATE March 22, 1999

1. BACKGROUND

This application is for a change of condition # 8389 for the following source (current identification):

S-1 Chrome Plating Bath

Currently this source is permitted for a chrome throughput of 1.8 million amp-hours per year (12-month 

basis). The emission factor is conditioned to 0.033 mg/a-hr. Although this facility is classified as a small 

source, WRE has demonstrated an emission factor of 0.003 mg/a-hr.

WRE/ColorTech desires to increase their chrome plating tank throughput to 6 million amp-hours per year 

(12-month basis). This application will evaluate this increase in light of existing Regulation 11-8, the new 

State ATCM, the federal NESHAP as well as the previous AB-2588 health risk assessment and a recent 

health risk assessment. For the purposes of current permit requirements, the new State ATCM has been 

deemed to be equivalent (or more stringent) to the Federal chrome plating NESHAP. Hence, compliance 

with the State ATCM (District regulation 11 Rule 8) will ensure compliance with the Federal NESHAP. 

Permit conditions will be revised accordingly.

The source will hereafter be more clearly identified as:

S-1 Hard Chrome Plating Tank Abated by A2 Duall Chrome Mist Eliminator & A3 

HEPA Filtration Unit 

For the purposes of Regulation 11 Rule 8, this permit application amounts to a modification, and will be 

subject to the permitting and operating requirements of modified hard chrome plating sources.

2. EMISSION CALCULATIONS

S-1 Chrome Plating Bath Abated by A2 Chrome Mist Eliminator & A3 HEPA Filtration Unit

WRE/ColorTech applied for a throughput increase to 6 MM a-hr/yr. They also plan to increase their stack 

height to 13 meters above grade. Based on the results of our risk screening analysis, the emission rate at a 6 

MM a-hr/yr throughput would be 0.0642 lb/yr (10/MM risk to residential MEI).

• Previous Maximum Hex Chrome Emissions = [1,800,000 ampere-hours/yr]*[0.033 mg hex 

chrome/ampere-hour)/[454,000 mg/lb] =0.131 lb/yr

• Proposed Maximum Hex Chrome Emissions = [6,000,000 ampere-hours/yr]*[0.005 mg hex 

chrome/ampere-hour)/[454,000 mg/lb] = 0.06 lb/yr (10 in a million risk based)

• Estimated Actual Hex Chrome Emissions = [6,000,000 amp-hr/yr]*[0.003 mg/a-hr]/454E3 

mg/lb = 0.04 lb/yr
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3. PERMIT REQUIREMENTS/DISCUSSION OF EXEMPTION

WRE/ColorTech is required to comply with BAAQMD Regulation 11-8 for chrome, Reg 2-1-316 (New or 

Modified Sources of Toxic Air Contaminants), the Federal Chrome Plating NESHAP. In November, Reg 

11-8 was amended to adopt the State ATCM by reference. At this time, there are no exemptions associated 

with this source. Since this application is for an increase in the permitted throughput, this application is 

defined as a modification and will be subject to the appropriate requirements.

4. BEST AVAILABLE CONTROL TECHNOLOGY

Regulation 11 Rule 8 represents TBACT for chrome plating facilities. The specific requirement for this 

modified chrome plating facility is a controlled outlet emission factor of 0.03 mg/a-hr. A source test 

conducted in 1993 demonstrated a hex chrome emission factor of 0.003 mg/a-hr. Since the demonstrated 

emission factor is well below the TBACT emission factor we conclude that WRE/ColorTech meets the 

criteria of TBACT for this source.

This source will be subject to the following specific requirements of Reg 11-8:

Maximum emission factor (per 11-8): 0.03 mg/a-hr (c)(1)(B)

Use of existing performance test: Normally the District would choose to accept a previous source test to 

demonstrate compliance as long as the source test was approved by the District and the US EPA. In this 

case since WRE/ColorTech is accepting an incrementally more restrictive emission factor, and since it has 

been 5 yrs since the previous source test, a new source test will be required.

Parameter Monitoring:

(e)(1) Ampere-hours

(e)(2) Pressure drop

Inspection and Maintenance:

(f)(1) Visual inspections @ frequency + washdown of the mist eliminator system as per mfr. 

recommendations + a-hr meter—per mfr. instructions.

Operation and Maintenance Plan

(g)(1) Preparation of O&M plan

(g)(2) Retain the O&M plan

(g)(3) Changes to the O&M plan

(g)(4) Revisions to address breakdowns

Recordkeeping

(h)(1) Inspection records- add-on pollution control devices

(h)(2) Inspection records – chemical fume suppressants

(h)(3) Performance test records

(h)(4) Monitoring data records

(h)(5) Breakdown records

(h)(6) Records of excesses

(h)(7) Records demonstrating facility size

(h)(8) Records of fume suppressant additions

(h)(11) Records retention

Reporting

(i)(3)(A)(2) Ongoing compliance (content identified on Appendix 3)

(i)(4) Reports of breakdowns

5. OFFSETS

Offsets are not applicable in this permit application.
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6. TOXIC EVALUATION

A risk evaluation was performed for WRE/ColorTech by Woodward-Clyde Engineers for AB-2588. After 

re-examining this previous risk assessment it appears that it cannot be used for the purposes of this 

evaluation since the emission release parameters have changed since the risk assessment was first 

performed.

Accordingly District staff has performed a new risk screening using ISCST-3 with conservative 

meteorology – at both urban and rural settings to determine the most conservative case. WRE/ColorTech 

has agreed to increase their stack height from 10 meters above grade to 13 meters. Emission parameters 

used in the modeling are as follows:

Emission level: 1 lb/yr

Flowrate: 1142 cfm

Stack Height: 10m, 13m, 15m

Stack Diameter: 8” (A= 0.3491 sq ft)

Velocity: 55 ft/sec

Risk Screening Results:

Topography: Rural (most conservative)

At 13 meter stack height:

MEI Residential Risk: 156 in a million

MEI Industrial Risk: 103 in a million

• Maximum chrome emission @10E-06 risk level to MEI: (1.0 lb/yr)(10E-06/156E-06) = 

0.064lb/yr:

• Maximum emission factor at 0.064 lb/yr: (0.064 lb/yr)(454E3 mg/lb)/6 MM a-hr/yr) = 0.005 

mg/a-hr

The risk level of 10/MM is within District toxic risk guidelines as long as TBACT controls are employed. 

The TBACT level of control is 0.03 mg/a-hr (based on Reg 11-8). Since the proposed level of control is an 

emission factor of 0.005 mg/a-hr we conclude that the proposed chrome emission rate represents a level of 

control that is better than TBACT. This application complies with the requirements of District toxic risk 

policy.

7. STATEMENT OF COMPLIANCE

This source complies with District Regulation 2-1-316 for air toxic contaminants as well as Regulation 11-8 

for the control of emissions from hard chrome plating operations. The existing permit conditions listed in 

Condition 8012 will be archived. The new condition for this source will be Condition # 16358.

8. CONDITIONS

Recommend accepting the new Condition 16358 to bring the requirements for this source up to 

date with District/State and Federal regulations.

Also recommend changing the source description to:

S-1 Hard Chrome Plating Tank Abated by Wetting Agent Bath Additive & A2 

Duall Composite Mesh Pad (CMP) Scrubber, followed by A3 HEPA 

Filtration System
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1. Annual Usage

The total annual (net) throughput from chrome plating tank S-1 shall not exceed 6 million amperehours in any consecutive twelve-month period.

2. Abatement

This source shall not be operated unless all chrome plating tank emissions are vented through A2 

Duall Composite Mesh Pad (CMP) System and A3 HEPA Filtration System. All emissions shall 

be exhausted from P1 at a height of at least 43 feet (13 meters) above grade. The abatement 

system shall be well maintained and kept in good operating condition.

3. Emission Limits

Emissions of hexavalent chromium shall not exceed 0.005 milligram per ampere-hour (mg/a-hr) 

after abatement.

4. Source Test

Initial Compliance Source Test: To demonstrate compliance with condition 3 above, 

WRE/ColorTech must perform a District-approved source test (according to a District approved 

protocol) on the exhaust stack within 60 days of permit approval. All source tests used to 

demonstrate compliance shall determine the mass emissions of both total and hexavalent chromium 

in g/hr, mg/a-hr, and mg/dscm as emitted after abatement. A complete report shall be submitted to 

the District’s Source Test Manager within 60 days of the source test and shall demonstrate 

compliance with Condition 3, above. 

Ongoing Compliance Source Testing: To demonstrate ongoing compliance with Condition 3, 

above, WRE/ColorTech shall perform a District approved source test according to the above 

specifications, at a frequency not to exceed 24 months. If after 2 such ongoing compliance source 

tests, no exceedances are noted, WRE/ColorTech may petition the District to rescind the 

requirement for ongoing compliance source testing in lieu of process parameter monitoring.

5. Parameter Monitoring

a) To demonstrate compliance with Condition 1, above, WRE/ColorTech shall install, operate 

and maintain a continuous recording, non-resettable ampere-hour meter that operates on the 

electrical power lines connected to the tank rectifier. A separate meter shall be hard-wired 

for each rectifier if applicable.

b) WRE/ColorTech shall continuously monitor the pressure drop across A2 composite mesh 

pad scrubber. The gauge shall be located so that it can be easily visible and in clear sight of 

the operation or maintenance personnel. The pressure drop shall be maintained within + 1 

inch of water of the value established during the performance test to demonstrate compliance 

with the emission limitation. 

c) WRE/ColorTech shall continuously monitor the pressure drop across A3 HEPA Filtration 

Unit. The gauge shall be located so that it can be easily visible and in clear sight of the 

operation or maintenance personnel. The pressure drop across the HEPA Filtration Unit 

shall not exceed 2 inches W.G. Upon reaching 2 inches W.G. WRE/ColorTech shall replace 

the old HEPA prefilter with a new HEPA prefilter. If the pressure drop across the HEPA 

Filtration Unit is still greater than 1.5 inches of water, WRE/ColorTech shall replace the 

HEPA filter component.
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6. Inspection/Maintenance

a) WRE/ColorTech shall perform visual inspections of the composite mesh pad scrubber A2 

and A3 HEPA Filtration Unit at a frequency of at least one time per calendar quarter. This 

visual inspection is to ensure that there is proper drainage, no unusual chromic acid buildup 

on the pads, and no evidence of chemical attack that would affect the structural integrity of 

the devices.

b) WRE/ColorTech shall visually inspect the back portion of the mesh pad closest the stack at a 

frequency of at least one time per quarter to ensure there is no breakthrough of chromic acid 

mist.

c) WRE/ColorTech shall visual inspect ductwork from tank to the control device at a frequency 

of at least one time per calendar quarter to ensure there are no leaks.

d) WRE/ColorTech shall perform washdowns of the composite mesh pads at a frequency as 

recommended by the manufacturer

e) The ampere-hour meter shall be installed and maintained as per manufacturer’s 

recommendations.

7. Operation and Maintenance Plan

a) WRE/ColorTech shall prepare an operation and maintenance (O & M) plan. The plan shall 

incorporate the inspection and maintenance requirements as noted in Condition 6, above, and 

shall include the following elements: a) a standardized checklist to document the operation 

ad maintenance of the source, the add-on air pollution control devices, and the process and 

control system monitoring equipment, and b) procedures to be followed to ensure that 

equipment is properly maintained.

b) O & M plan retention: WRE/ColorTech shall keep the written operation and maintenance 

plan on record after it is developed to be made available for District inspection, upon request.

c) Changes to the O & M plan: Any changes made to the O & M Plan should document in an 

addendum to the plan. In addition, WRE/ColorTech shall keep previous versions of the O & 

M Plan on record to be made available for District inspection upon request, for a period of 5 

year after each revision to the plan.

d) Revisions to address breakdowns: The O & M Plan shall be revised as necessary to 

minimize breakdowns.

To satisfy the inspection and maintenance procedures, WRE/ColorTech may use applicable 

standard operating procedure (SOP) manuals, Occupational Safety and Health Administration 

(OSHA) plans, or other existing plans, provided the alternative plans meet the requirements of this 

subsection.

8. Recordkeeping

The following records shall be kept and maintained by WRE/ColorTech for at least five years 

total; and at least two years on site.

a) Inspection records for A2 composite mesh pad scrubber and A3 HEPA Filtration Unit: 

WRE/ColorTech shall maintain inspection records to document that the 

Inspection/Maintenance requirements and the O & M Plan as required by Conditions 6 and 7, 

above, respectively have been met. The record can take the form of a checklist and should 

identify 1) the device inspected, 2) the date and time of the inspection, 3) a brief description 

of the working condition of the device during inspection, 4) maintenance activities performed 

on the components of the air pollution control system (i.e. ductwork, filter pad, fan, etc), and 

5) any action taken to correct deficiencies found during inspection.

b) WRE/ColorTech shall maintain records to demonstrate that the inspection and maintenance 

requirements of Condition 6, above, have been satisfied.
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c) Performance test records: WRE/ColorTech shall maintain test reports documenting the 

conditions and results of all performance tests.

d) Monitoring data records: WRE/ColorTech shall maintain records of monitoring data as 

required by Conditions 1 and 5, as follows:

e) Breakdown records: WRE/ColorTech shall maintain records of the occurrence, duration, and 

cause (if known) and action taken on each breakdown.

f) Records of excesses: WRE/ColorTech shall maintain records of exceedances of: a) the 

emission limitation identified in Condition 3; b) the monitoring parameter values of 

Condition 5; c) any site-specific operating parameters established for alternative equipment. 

The records shall include the date of the occurrence, the duration, cause (if known), and 

where possible, the magnitude of any excess emissions.

9. Reporting

a) On an annual basis, WRE/ColorTech shall prepare a summary report to the District to 

document the ongoing compliance status. This report shall be made available to the District 

upon request.

b) Breakdown reports: WRE/ColorTech shall report breakdowns as required by the District 

breakdown procedures identified in Regulation 1.

9. RECOMMENDATIONS

Archive Condition 8012, adopt Condition 16358 for source S1 at WRE/ColorTech America Co and reissue/include in revised Permit to Operate for S1.

NOTE: AS PER THE PERFORMANCE SOURCE TEST OF 9/13/2001, THE CONDITION #16358 

SHALL BE CHANGED AS FOLLOWS: CONDITION REVISIONS SHOWN UNDERLINED. This 

is processed as an administrative permit condition change. (9-4-2002), REF

1. Annual Usage 

 The total annual (net) throughput

 from chrome plating tank S-1 shall

 not exceed 6 million ampere-hours

 in any consecutive twelve-month

 period. 

2. Abatement 

 This source shall not be operated

 unless all chrome plating tank

 emissions are vented through A2 Duall

 Composite Mesh Pad (CMP) System and A3

 HEPA Filtration System. All emissions

 shall be exhausted from P1 at a height

 of at least 43 feet (13 meters) above

 grade. The abatement system shall be

 well maintained and kept in good

 operating condition. 

3. Emission Limits 

 Emissions of hexavalent chromium shall

 not exceed 0.005 milligram per ampere-
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 hour (mg/a-hr) after abatement. 

4. Source Test 

 Initial Compliance Source Test: To

 demonstrate compliance with condition

 3 above, WRE/ColorTech must perform a

 District-approved source test

 (according to a District approved

 protocol) on the exhaust stack within

 60 days of startup. All source

 tests used to demonstrate compliance

 shall determine the mass emissions of

 both total and hexavalent chromium in

 g/hr, mg/a-hr, and mg/dscm as emitted

 after abatement. A complete report

 shall be submitted to the District's

 Source Test Manager within 60 days of

 the source test and shall demonstrate

 compliance with Condition 3, above. 

 Ongoing Compliance Source Testing:

 To demonstrate ongoing compliance

 with Condition 3, above, WRE/ColorTech

 shall perform a District approved

 source test according to the above

 specifications, at a frequency not to

 exceed 24 months. If after 2 such

 ongoing compliance source tests, no

 exceedances are noted, WRE/ColorTech

 may petition the District to rescind

 the requirement for ongoing compliance

 source testing in lieu of process

 parameter monitoring. 

5. Parameter Monitoring 

 a) To demonstrate compliance with

 Condition 1, above, WRE/ColorTech

 shall install, operate and maintain

 a continuous recording, non-

 resettable ampere-hour meter that

 operates on the electrical power

 lines connected to the tank rectifier.

 A separate meter shall be hard-wired

 for each rectifier if applicable. 

 b) WRE/ColorTech shall continuously

 monitor the pressure drop across

 A2 composite mesh pad scrubber.

 The gauge shall be located so that

 it can be easily visible and in

 clear sight of the operation or

 maintenance personnel. The

 pressure drop shall be maintained

 within plus or minus 1 inch of water of the

 value established during the

 performance test to demonstrate

 compliance with the emission

 limitation. 
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 c) WRE/ColorTech shall continuously

 monitor the pressure drop across

 A3 HEPA Filtration Unit. The gauge

 shall be located so that it can be

 easily visible and in clear sight

 of the operation or maintenance

 personnel. The pressure drop

 across the HEPA Filtration Unit

 shall be maintained between 0.275

 and 1.10 inches W.G. (based on the

 source test of 09/13/2001). Upon

 reaching 1.10 inches W.G. WRE/ColorTech

 shall replace the existing HEPA

 prefilter with a new HEPA prefilter.

 If the pressure drop across the HEPA

 Filtration Unit is still greater than

 1.10 inches of water, WRE/ColorTech

 shall replace the HEPA filter

 component.

 (Basis: Reg 11 Rule 8 (e)(2)) 

6. Inspection/Maintenance 

 a) WRE/ColorTech shall perform visual

 inspections of the composite mesh

 pad scrubber A2 and A3 HEPA

 Filtration Unit at a frequency of

 at least one time per calendar

 quarter. This visual inspection

 is to ensure that there is proper

 drainage, no unusual chromic acid

 buildup on the pads, and no

 evidence of chemical attack that

 would affect the structural

 integrity of the devices.

 b) WRE/ColorTech shall visually inspect

 the back portion of the mesh pad

 closest the stack at a frequency

 of at least one time per quarter

 to ensure there is no breakthrough

 of chromic acid mist.

 c) WRE/ColorTech shall visual inspect

 ductwork from tank to the control

 device at a frequency of at least

 one time per calendar quarter to

 ensure there are no leaks.

 d) WRE/ColorTech shall perform

 washdowns of the composite mesh

 pads at a frequency as recommended

 by the manufacturer.

 e) The ampere-hour meter shall be

 installed and maintained as per

 manufacturer's recommendations. 

7. Operation and Maintenance Plan 

 a) WRE/ColorTech shall prepare an

 operation and maintenance (O & M)

 plan. The plan shall incorporate

 the inspection and maintenance

 requirements as noted in Condition
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 6, above, and shall include the

 following elements:

 1) a standardized checklist to

 document the operation and

 maintenance of the source, the

 add-on air pollution control

 devices, and the process and

 control system monitoring

 equipment, and

 2) procedures to be followed to

 ensure that equipment is

 properly maintained.

 b) O & M plan retention:

 WRE/ColorTech shall keep the

 Written operation and maintenance

 plan on record after it is

 developed to be made available for

 District inspection, upon request.

 c) Changes to the O & M plan:

 Any changes made to the O & M

 Plan should document in an addendum

 to the plan. In addition,

 WRE/ColorTech shall keep previous

 versions of the O & M Plan on

 record to be made available for

 District inspection upon request,

 for a period of 5 year after each

 revision to the plan.

 d) Revisions to address breakdowns:

 The O & M Plan shall be revised

 as necessary to minimize breakdowns. 

 To satisfy the inspection and

 maintenance procedures,

 WRE/ColorTech may use applicable

 standard operating procedure (SOP)

 manuals, Occupational Safety and

 Health Administration (OSHA) plans,

 or other existing plans, provided

 the alternative plans meet the

 requirements of this subsection. 

8. Recordkeeping 

 The following records shall be kept

 and maintained by WRE/ColorTech for

 at least five years total; and at

 least two years on site. 

 a) Inspection records for A2

 composite mesh pad scrubber and

 A3 HEPA Filtration Unit:

 WRE/ColorTech shall maintain

 inspection records to document

 that the Inspection/Maintenance

 requirements and the O & M Plan as

 required by Conditions 6 and 7,

 above, respectively have been met.

 The record can take the form of a

 checklist and should identify

 1) the device inspected, 2) the
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 date and time of the inspection,

 3) a brief description of the

 working condition of the device

 during inspection, 4) maintenance

 activities performed on the

 components of the air pollution

 control system (i.e. ductwork,

 filter pad, fan, etc), and 5) any

 action taken to correct

 deficiencies found during

 inspection.

 b) WRE/ColorTech shall maintain

 records to demonstrate that the

 inspection and maintenance

 requirements of Condition 6,

 above, have been satisfied.

 c) Performance test records:

 WRE/ColorTech shall maintain test

 reports documenting the conditions

 and results of all performance

 tests.

 d) Monitoring data records:

 WRE/ColorTech shall maintain

 records of monitoring data as

 required by Conditions 1 and 5,

 as follows:

 e) Breakdown records: WRE/ColorTech

 shall maintain records of the

 occurrence, duration, and cause

 (if known) and action taken on

 each breakdown.

 f) Records of excesses:

 WRE/ColorTech shall maintain

 records of exceedances of:

 1) the emission limitation

 identified in Condition 3;

 2) the monitoring parameter values

 of Condition 5; c) any

 site-specific operating

 parameters established for

 alternative equipment. The

 records shall include the date

 of the occurrence, the duration,

 cause (if known), and where

 possible, the magnitude of any

 excess emissions. 

9. Reporting 

 a) On an annual basis, WRE/ColorTech

 shall prepare a summary report to

 the District to document the

 ongoing compliance status. This

 report shall be made available to

 the District upon request.

 b) Breakdown reports: WRE/ColorTech

 shall report breakdowns as required

 by the District breakdown procedures

 identified in Regulation 1.
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by:

Randy E. Frazier, P.E.