ENGINEERING EVALUATION REPORT

PLANT NAME Johnson Plating Works

APPLICATION NUMBER 19115

PLANT NUMBER 3490

DATE 11

- 13

- 2008

1. BACKGROUND

On October 24, 2007, a major revision to the Airborne Toxic Control Measure (ATCM) for

Chromium Plating and C hromic 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 so urces

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 Co ntrol Abatement

- 1 Abatement

- 2

1 1784 24178 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 wa s reviewed 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 measurement 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 less than 330 feet from the nearest sensitive receptor. The ATCM allows

facilities t o operate at throughputs up to 2 0,000 amp

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

located less than 330 feet from the nearest sensitive receptor. This facility was previously

conditioned to a throughput of 3 0,000 amp

- hr/hr, therefore the throughput will decrease to 20,000

.

Basis Throughput, a

- hr/yr Factor, mg/a

- hr Emissions, lb/yr

Current 3 0,000 0.01 0.00 066

Post

- ATCM 20 ,000 0.01 0.00 044

Net Difference 10,00 0 0 0 .00022AN 19115/Johnson Plating Works (Plant A3490)

RE Frazier, P.E.

11/13/2008

2 3. CEQA

Since the permitted emission levels decrease , this application is exempt from CEQA review per

Reg 2

- 1

- 312.1.

4. BEST AVAILABLE CONTROL TECHNOLOGY

Emission levels decrease

, therefore BACT is not applicable.

5. EXEMPTIONS

There are no applicable exemptions.

6

. OFFSETS

Offsets are not applicable, since emissions decrease , therefore no offset triggers are exceeded.

7

. TOXIC EVALUATION

Permitted emission levels decrease , therefore no toxic evaluation is required. Previous tox ic 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 t he emission levels are reduced , we do not expect risk levels to increase

.

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 1784 is presented in this application, as is the new Template

Condition 2417 8

. Condition 2417 8 is written in general terms for any facility located less than 330

feet from any sensitive receptor, with permitted throughput of less than or equal to 2 0,000 amp

hr/yr.

10. RECOMMENDATIONS

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

Condition 24178

.

OLD CONDITION 21262

COND# 1784

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

1) ThroughputAN 19115/Johnson Plating Works (Plant A3490)

RE Frazier, P.E.

11/13/2008

3 The total annual combined throughput at source S

- 1 shall

not exceed 30,000 amp

- hrs in any consecutive twelve month

period.

2) Amp

- hours of ope ration

To comply with the above condition, Johnson 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 without the simultaneous operation of

the ampere

- hour meter.

3) Abatement

- Plating Bath Surface Tension

Source S

- 1 shall not be operated unless the plating bath

is operated with McGean Rohco Dis

- mist NP UN1760 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 condition 3, above,

surface tension of source S

- 1 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

surface 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 frequency

can be further reduced to "at least one time every 40,000

amp

- hours of bath operation".

5) Surface Tension Mo nitoring

- Testing Methods

Surface tension testing shall be conducted as specified

in EPA Method 306

- B by the use of a stalagmometer or

preciser tensiometer as directed by manufacturers

instructio ns. Alternate test methods may also be used if

the method has been appropriately validated using EPA

Method 301, Appendix A, 40 CFR Part 63.

6) Initial Performance Testing

- Required Records

In the process of conducting the initial performanceAN 19115/Johnson Plating Works (Plant A3490)

RE Frazier, P.E.

11/13/2008

4 testing, the following records shall be kept:

a) Sampling and analysis procedures.

b) Raw data sheets.

c) Documentation of calculations.

d) Source t esting results.

7) Recordkeeping

Johnson Plating shall keep and maintain the following

records associated with source S

- 1:

a) Performance test records.

b) Operating throughput records (monthly, amp

- hour

throughput)

c) Records of chemical additions to chrome plating bath.

8) Reporting

J ohnson Plating shall provide 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) Ret ention of Records

Johnson 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 CONDITION 24178

COND# 24178

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

The owner/operator shall comply with the following

Conditions for the hexavalent chrome plating source(s).

Basis refers to eit her BAAQMD Regulations/Rules or

California Code of Regulations, Title 17, Section 93102

- 93102.16 and associated appendices, unless otherwise noted.

Web address: http://www.arb.ca.gov/toxics/atcm/chroatcm.pdf

1. Performance Standard s

Throughput: The total annual throughput shall not

exceed 20,000 ampere

- hours in any consecutive 12

- month

period. [Basis: 93102.4(b)(1)]AN 19115/Johnson Plating Works (Plant A3490)

RE Frazier, P.E.

11/13/2008

5 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 ba th 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

(Manufacturer) (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 opera tor or current

employee who is onsite 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 closed

container in an enclosed storage area.

b) Chromic acid materials shall be transported from

storage to the bath in a closed container.

c) Any liquid or sold 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:AN 19115/Johnson Plating Works (Plant A3490)

RE Frazier, P.E.

11/13/2008

6 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

solut ion 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 waste s 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 insta lled and maintained

per manufacturer's specifications. The

owner/operator shall record the total ampere

- hours

used during each month.

[Basis: 93102.9(a), 93102.12(c)(1)]

b) Sur face 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 th e 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 occ urs, the measurement frequency shall

return to daily for 20 operating days, and weekly

thereafter. [Basis: 93102.9(d), 93102.12(c)(4)]

Surface Tension Testing Methods: If using a

Tensiometer, test me thod 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. [Basi s: 93102.7(c)(3)]AN 19115/Johnson Plating Works (Plant A3490)

RE Frazier, P.E.

11/13/2008

7 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 a nd 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

chrome plating bath, amp

- hr meter(s)/totalizers,

stalagmometer or tensiometer. [Bas is: 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) 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 check list 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:

[ 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

rectifier ampere

- hour totals.

c) Breakdown Records noting the occurrence,

duration, cause (if known), and action taken.

d) Records of excesses of the ampere

- hou r

limitations of Part 1 or the surface tension

limits of Part 2.

e) Housekeeping Records demonstrating compliance

with Part 4, above, including date and time of

housekeeping activity.

8) ReportingAN 19115/Johnson Plating Works (Plant A3490)

RE Frazier, P.E.

11/13/2008

8 The owner or operator shall submit an annual compliance

status report to the District [Compliance & Enforcement

Division] on or before February 1, and shall include the

following information for the preceding calendar year.

1. Company Information

a.Facility Name & Plant Number:

b.Facility Address:

c.Facilit y 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 monit oring, processes, or

controls since 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 we re

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 Compliance Training

Program.

Name: Name:

Title: Title:

Name:

Title:

Report Certified by:

Title:AN 19115/Johnson Plating Works (Plant A3490)

RE Frazier, P.E.

11/13/2008

9 Date:

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