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 application 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 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

Source tests of the existing units A-6, A-7 and A-8 have easily complied 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 

current 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 scrubber 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 within acceptable levels. No further risk evaluation 

is necessary.
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5. PERMIT REQUIREMENTS/DISCUSSION OF EXEMPTION

Not applicable.

6. DETERMINATION OF COMPLIANCE

A. Regulation 1 – General Provisions and Definitions

§1-301: Prohibits discharging emissions 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 complying 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. Permits – 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 exisiting 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 emissions 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 operators. 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 exhaust 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 is 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. 
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BAAQMD Plant 4449

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7. CONDITIONS

Recommend the revised Condition 23126 for the following sources:

S-2 Hard Chrome 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 refers 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 requirements 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] 
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 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: 93102.4(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 standard specified

 in Part 1. 

 By October 24, 2009, the owner/operator shall

 perform a source test to demonstrate compliance with

 the emission performance standard specified 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 which 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
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 plating operation and associated emission control

 system. A source test to demonstrate compliance

 shall be performed no later than 30 days 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 have 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 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 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 shall 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. 
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 c) Any liquid or solid hexavalent 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 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, 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

 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 Scrubber 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 frequency 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
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 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 drop 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/operator 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 maintenance 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 conduct 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 the 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
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 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 

 i. record monthly and cumulative 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,

 duration, 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 ampere-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: The 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,
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 title and signature of the responsible 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 A6, A-7, A-8 with all emissions vented through A-9 HEPA Filter Unit, subject to revised Condition # 23126.

By:

Randy E. Frazier, P.E.

Senior Air Quality Engineer

2 December 2008