ENGINEERING EVALUATION REPORT

PLANT NAME Electrocoatings of Berkeley

APPLICATION NUMBER 19108

PLANT NUMBER 4449

DATE 2 December 2008

1. BACKGROUND

Electrocoatings (ECI) of Berkeley has filed this application to install a new HEPA filter unit to meet the

0.0015 mg/a

- hr requirements of the new CARB Chrome Plating and Anodizing ATCM. The applicant has

also expressed an interest in returning the throughput level to 38.4 million amp

- hr/yr, which was the

permitted throughput level, prior to applicati on 14348, which lowered the throughput to 23 million am

- hr/yr.

The unit which is being installed is: A

- 9 ScrubAir HEPA Filter System

The units which are to be abated by this HEPA filter are as follows:

S

- 2 Hard Chrome Plating Bath

- Tank #3 Abated b y A

- 6 3

- Stage ScrubAir System

S

- 4 Hard Chrome Plating Bath

- Tank #7 Abated by A

- 7 3

- Stage ScrubAir System

S

- 8 Hard Chrome Plating Bath

- Tank #1 Abated by A

- 8 3

- Stage ScrubAir System

Source tests of the existing units A

- 6, A

- 7 and A

- 8 have easily co mplied with the existing condition emission

factor of 0.0061 mg/a

- hr. The addition of the HEPA unit is fully expected to achieve 0.0015 mg/a

- hr.

A new HRSA is not required as the proposed final configuration results in an emission reduction from

curren t levels.

2. EMISSION CALCULATIONS

Pre

- project maximum allowed (permitted) emissions: (23.0 E6 amp

- hr/yr)(0.0061 mg/amp

- hr)(lb/454E3 mg)

= 0.309 lb/yr

Post

- project maximum allowed (permitted) emissions: (38.6 E6 amp

- hr/yr)(0.0015 mg/a

- hr)(lb/454E3 mg) = 0.127 lb/yr

Project emission decrease, %: (0.309

– 0.127)/0.309 = 59% reduction (0.182 lb/yr

decrease)

3. TOXIC EVALUATION

The latest HRSA was performed in 2006 as part of AN 14348, for the installation of the A

- 6, A

- 7 and A

- 8

ScrubAir 3

- Stage scrubb er systems. The HRSA was performed using exhaust flow and emissions data

(based on 0.309 lb hex chrome/yr) in conjunction with the meteorological data from the nearby (within

BLOB) EBMUD wastewater treatment facility. The results of that HRSA was an MEI risk level of 9.9 in a

million for the nearest residential receptor and 7.4 in a million for the nearest industrial receptor.

With a 59% reduction in hex chrome emissions we expect the maximum risks to decrease to 4.1 in a million

for the residential MEI and 3 in a million for the industrial MEI. The application of equipment with results in

an emission rate of 0.0015 mg/a

- hr is representative of TBACT for chrome plating operations. This facility

is in compliance with toxic NSR (Reg 2

- 5). All risks are w ithin acceptable levels. No further risk evaluation

is necessary.**Electrocoatings Inc.**

**BAAQMD Plant 4449**

**AN 19108; 2 Dec**  **2008**

**REFra zier** 

2 5. PERMIT REQUIREMENTS/DISCUSSION OF EXEMPTION

Not applicable.

6. DETERMINATION OF COMPLIANCE

A

. Regulation 1

– General Provisions and Definitions

§1

- 301: Prohibits discharging em issions in quantities that cause injury, detriment,

nuisance, or annoyance. There were no violations of 1

- 301 prior to this project. Since

this project results in a 59% reduction in emissions , we have no reason to expect there

will be any difficulty comp lying with this requirement in the future.

B. Permits

– General Requirements, Regulation 2 Rule 1

The source is not located within 1000 feet of the nearest school, and is therefore not

subject to the public notification requirements of 2

- 1

- 412.

C. Pe rmits

– New Source Review, Regulation 2 Rule 2 (dated 10/7/98)

1. BACT: The latest version of the chrome plating ATCM requires a maximum hex

chrome emission limit of 0.0015 mg/a

- hr. The use of the proposed HEPA Filter

Unit in conjunction with the exis iting 3

- stage ScrubAir units to achieve the 0.0015

mg

- a

- hr standard constitutes BACT for a hard chrome plating operation.

2. Offset Requirements: §2

- 2

- 303: Offsets are not applicable to this project.

3

. Prevention of Significant Deterioration: §2

- 2

- 304: PSD requirements are not

applicable.

D. Regulation 3

– Fees

ECI has complied with the fee requirements for this application.

E. Particulate Matter and Visible Emissions, Regulation 6

1

. Section 301 prohibits for more than 3 minutes per hour, visible emiss ions as

dark or darker than Ringelmann 1 or equivalent opacity. Visible emissions have

never been an issue at this facility. No change is expected.

2

. Section 305 prohibits emissions of visible particles from causing a nuisance on

property other than the o perators. The aforementioned sources have never

created a nuisance and with the expected reduced emissions are not expected

to create a nuisance in the future.

3

. Section 310 limits the particulate concentration in exhaust gases to 0.15 gr/dscf.

At an exha ust rate well over 15,000 cfm and an annual chrome emission of

approximately 0.13 lb/year we expect these sources will have no difficulty in

complying with the emission limitations of 6

- 310.

F. NSPS/NESHAPS

Although the latest version of the California chrome plating ATCM has not been granted

equivalency with the federal NESHAP, there is no reason to expect that the new

requirements would not exceed in every way, the federal requirements. The previous

ATCM was granted equivalency and the current ATCM i s significantly more stringent,

therefore, it is fully expected that no further review of federal requirements are needed.

G. CEQA

This project is considered to be ministerial under the District’s CEQA Regulation 2

- 1

- 311.

The engineering review for this project requires only the application of standard permit

conditions and standard emissions factors and therefore is not discretionary as defined by

CEQA.**Electrocoatings Inc.**

**BAAQMD Plant 4449**

**AN 19108; 2 Dec**  **2008**

**REFra zier** 

3 7. CONDITIONS

Recommend the revised Condition 23126 for the following sources:

S

- 2 Hard Ch rome Plating Bath

- Tank #3 Abated by A

- 6 3

- Stage ScrubAir System

S

- 4 Hard Chrome Plating Bath

- Tank #7 Abated by A

- 7 3

- Stage ScrubAir System

S

- 8 Hard Chrome Plating Bath

- Tank #1 Abated by A

- 8 3

- Stage ScrubAir System

Emissions from A

- 6, A

- 7and A

- 8 abated by A

- 9 HEPA Filter Unit

COND# 23126

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

The owner/operator shall comply with the following

Conditions for Sources 2, 4, and 8 (chrome plating tanks #3,

7, and 1, respectively). Basis refer s to either BAAQMD

Regulations/Rules or California Code of Regulations, Title

17, Section 93102

- 93102.16 and associated Appendices,

unless otherwise noted)

1. Performance Standards

a) Emission Limits effective through 10

- 23

- 2009:

Emissions of hexavalent chromium shall not exceed

0.0061 mg per ampere

- hour (mg/amp

- hr) after

abatement. [Basis: 93102.4(a)(1)]

b) Emission Limits effective 10

- 24

- 2009:

Emissions of hexavalent chromium shall not exceed

0.0015 mg per ampere

- hour (mg/amp

- hr) after

abatement.

[Basis: 93102.4(b )(1)]

c) Throughput: The total annual combined throughput

shall not exceed 38.6 million ampere

- hours in any

consecutive 12

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

d) The requiremen ts of Parts 1a and 1b of this

condition and the O&M Plan provision do not apply

during periods of equipment breakdown, provided the

provisions of the District's breakdown rules are

met. [Basis: 93102.2( b)]

2. Abatement

a) The owner/operator shall abate at all times during

operation of S

- 2, S

- 4 and S

- 8 with A

- 6, A

- 7, and

A

- 8 (3

- stage ScrubAir Composite Mesh Pad Units),

respectively. [Basis: TBACT]**Electrocoatings Inc.**

**BAAQMD Plant 4449**

**AN 19108; 2 Dec**  **2008**

**REFra zier** 

4 b) The owner/operator shall abate at all times the flow

from A

- 6, A

- 7, and A

- 8 with A

- 9 ScrubAir HEPA

filter unit. [Basis: 9 3102.4(b)(1)]

The ventilation and abatement systems shall be

properly maintained and kept in good working

condition.

3. Source Testing

a) Within 60 days of startup of the A

- 9 ScrubAir HEPA

filter unit, the owner/operator shall perform a

source test to demonstrate compliance with the

applicable emission performance sta ndard specified

in Part 1.

By October 24, 2009, the owner/operator shall

perform a source test to demonstrate compliance with

the emission performance standard sp ecified in

Part 1b.

Any source test conducted to demonstrate compliance

with this Part shall be performed in accordance with

ATCM Section 93102.7(b) and (c).

[Basis: 93102.7(a)(1)(A)]

b) The owner/operator shall perform source tests to

demonstrate compliance according to the following

schedule:

i. Unless Part 3.b)ii. is satisfied, subsequent

source testing shall be performed no later

than 36 months after the date of the previous

District

- approved source test demonstrating

compliance.

ii. If the previous two consecutive source tests

demonstrate compliance, the subsequent tests

shall be performed no later than 48 months

after the previous source test.

iii. If a source test demonstrates non

- compliance,

then the owner/operator must perform another

source test to demonstrate compliance.

Subsequent source tests to demonstrate

compliance shall be performed no later than

24 months after the previous source test. If

after two consecutive source tests at the 24

month frequency, both of w hich demonstrate

compliance, the source test frequency reverts

to the original schedule in Part 3.b)i.

c) Non

- compliant source test: After conducting a

source test which demonstrates non

- compliance the

owner/operator shall review and adjust or repair the**Electrocoatings Inc.**

**BAAQMD Plant 4449**

**AN 19108; 2 Dec**  **2008**

**REFra zier** 

5 plating operation and associated emission control

system. A source test to demonstrate compliance

shall be performed no later than 30 d ays after the

chrome plating system adjustments/repairs are

completed.

d) Any chrome plating bath that is non

- operational at

the time a source test is due does not h ave to be

tested at that time. Upon subsequent start

- up of

any such bath, a source test shall be conducted

within 30 days.

e) Source Testing Protocol: A written source test

protocol based on 93102.7(c) shall be provided for

District approval prior to conducting any source

test for compliance. This source testing protocol

shall include testing methods, length of sample

period, plating facilities to be operated during the

source test, sampling equipment and methods, as well

as the planned date for the source test.

f) The owner/operator shall contact the District Source

Test Section at least 14 days in advance of the

source test or as directed by the ATCM to obtain

approval of the test protocol. The owner/operator

shall notify the District Source Test Section at

least 7 days in advance of each scheduled source

test. [Basis: 93102.7]

4. Training

No later than October 24, 2009, and within every tw o

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 c urrent

employee who is onsite and has completed the ARB

Compliance Assistance Training Course for chrome

plating and anodizing. [Basis: 93102.5(b)]

5. Housekeeping

The following housekeeping requirements shall be

implemented to reduce potential hexavalent chrome

fugitive emissions:

[Basis: 93102.5(c)]

a) Chromic acid materials shal l 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.**Electrocoatings Inc.**

**BAAQMD Plant 4449**

**AN 19108; 2 Dec**  **2008**

**REFra zier** 

6 c) Any liquid or sol i d hexav alent chrome containing

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 p arts 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, 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 b e

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.

6. 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: 93102.10(a),

93102.12(c)(1)]

b) Dry Scr ubber Pressure Drop: The owner/operator

shall continuously monitor the pressure drop across

A

- 6, A

- 7, and A

- 8 ScrubAir 3

- stage composite mesh

pad units. The pressure drop shall be maintained

within plus or minus 2 inches of water of the value

established during the most recent source test to

demonstrate compliance with the emission limitations

of Part 1. Pressure drop readings shall be recorded

at a fr equency of at least one time per operating

week. [Basis: 93102.9(b), 93102.12(c)(2)]

c) HEPA Filter Pressure Drop: The owner/operator shall**Electrocoatings Inc.**

**BAAQMD Plant 4449**

**AN 19108; 2 Dec**  **2008**

**REFra zier** 

7 continuously monitor the pressure drop across A

- 9

HEPA filter unit. The pressure drop shall be

maintained within minus 1⁄2 times to +2 times the

inches of water of the value established during the

most recent source test to demonstrate compliance.

Pressure dro p readings shall be recorded at a

frequency of at least one time per operating week.

[Basis: 93102.9(b), 93102.12(c)(2)]

7. Operation & Maintenance (O&M) Plan

The owner/operat or 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 maint enance requirements for the

air pollution control equipment and amp

- hr

meters/totalizers.

[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]

8. Inspection & Maintenance Frequency

a) The owner/operator shall perform visual inspections

of the abatement systems and associated ductwork

pursuant to ATCM Section 93102.10(a) at least once

per calendar quarter and co nduct maintenance of

the composite mesh pad scrubbers and HEPA unit per

manufacturer's recommendation.

[Basis: 93102.10(a) and Reg 2

- 5]

b) In order to demonstrate compliance with Part 8a,

the owner/operator shall record the equipment being

inspected, date, brief description of the working

condition of the device during the inspections, any

maintenance activities performed on th e components

of the air pollution control systems, and any

actions taken to correct deficiencies found during

the inspection.

9. Recordkeeping

The owner/operator shall maintain the following records**Electrocoatings Inc.**

**BAAQMD Plant 4449**

**AN 19108; 2 Dec**  **2008**

**REFra zier** 

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

maintained onsite.

a) Inspection Records to d emonstrate 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, t he date and

time of the inspection, a brief description of the

working condition and any corrective actions.

b) The owner/operator shall

i. record monthly and cumulativ e 12

- month

rectifier ampere

- hour totals and

ii. record the pressure drop across the

abatement device(s) at least once a week.

c) Breakdown Records noting the occurrence,

dur ation, cause (if known), and action taken.

d) Records of excesses of the emission limitations

set forth in Part 1 or the monitoring parameters

established under Part 6 noting any exceedances of

the am pere

- hour throughput or pressure drop limits.

e) Housekeeping Records demonstrating compliance

with Part 3, above, including date and time of

housekeeping activity.

10. Reporting

a) Source Test Reports: The owner/operator shall

report source test results used to demonstrate

compliance to the District Source Test Section no

later than 60 days after the test date. The content

of the source test reports shall contain the

information identified in Appendix 1 of the

applicable ATCM. Source test records shall be

maintained onsite at the facility and made available

to the District upon request, for a period of 5

years from the date of the source test. [Basis:

93102.13(a)]

b) Annual Compliance Status Report: T he owner/operator

shall submit an annual compliance status report to

the District on or before February 1, and shall

include the following information for the preceding

calendar year.

The content of the ongoing status shall include the

information identified in Appendix 3 of the

applicable ACTM. The report shall contain the name,**Electrocoatings Inc.**

**BAAQMD Plant 4449**

**AN 19108; 2 Dec**  **2008**

**REFra zier** 

9 title and signature of the responsibl e official who

is certifying the accuracy of the report. [Basis:



### 93102.13(c)]

8. RECOMMENDATIONS

Issue a new permit to operate for hard chrome plating tanks S

- 2, S

- 4, and S

- 8 abated by ScrubAir Units A

6, A

- 7, A

- 8 with all emi ssions vented through A

- 9 HEPA Filter Unit, subject to revised Condition # 23126.

By:

Randy E. Frazier, P.E.

Senior Air Quality Engineer

2 Decem ber 2008