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 identifi cation):

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 Regulat ion 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 stri ngent) 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 i dentified 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 operat ing 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 t o 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)

• Estima ted Actual Hex Chrome Emissions = [6,000,000 amp

- hr/yr]*[0.003 mg/a

- hr]/454E3

mg/lb = 0.04 lb/yrWRE/ColorTech America Co, Ltd P/A 18956

2/10/99

REFrazier 2 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 Sour ces 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 t he 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 requireme nt 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 perfor mance 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 restricti ve 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 + wash down 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 break downs

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.WRE/ColorTech America Co, Ltd P/A 18956

2/10/99

REFrazier 3 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 Heigh t: 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 ch rome 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 lon g 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 con trol 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) Scru bber, followed by A3 HEPA

Filtration SystemWRE/ColorTech America Co, Ltd P/A 18956

2/10/99

REFrazier 4 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 sha ll 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 determ ine 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

compl iance 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 excee d 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 mete r 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 o r 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 pressur e 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 reachi ng 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.WRE/ColorTech America Co, Ltd P/A 18956

2/10/99

REFrazier 5 6

. Inspect ion/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 drainag e, 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 le ast 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/C olorTech 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/Color Tech 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 oper ation

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 sha ll 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 exis ting 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 record s 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 t he 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

req uirements of Condition 6, above, have been satisfied.WRE/ColorTech America Co, Ltd P/A 18956

2/10/99

REFrazier 6 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 shal l 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 d ate 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 re

issue/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 UND ERLINED. 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 mill ion 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 ampe re

-WRE/ColorTech America Co, Ltd P/A 18956

2/10/99

REFrazier 7 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 com pliance

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

- wir ed

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 easi ly 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.WRE/ColorTech America Co, Ltd P/A 18956

2/10/99

REFrazier 8 c) WRE/ColorTech shall continuously

monitor the pressure drop across

A3 HEPA Filtration Unit. The gauge

shal l 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 inspec tion

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/C olorTech 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 composit e 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 P lan

a) WRE/ColorTech shall prepare an

operation and maintenance (O & M)

plan. The plan shall incorporate

the inspection and maintenance

requirements as noted in ConditionWRE/ColorTech America Co, Ltd P/A 18956

2/10/99

REFrazier 9 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

Wr itten 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 docu ment 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 af ter 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

leas t 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 devic e inspected, 2) theWRE/ColorTech America Co, Ltd P/A 18956

2/10/99

REFrazier 10 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 pol lution

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 th e

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. Th e

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.WRE/ColorTech America Co, Ltd P/A 18956

2/10/99

REFrazier 11 by:

Randy E. Frazier, P.E.