CCLME.ORG - DIVISION 3. AIR RESOURCES
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(continued)
(3) Water Curtain Monitoring Requirements
For thermal spraying operations that are conducted in water curtain booths, the owner or operator must monitor booth operating parameters during thermal spraying to ensure compliance with the requirements specified in subsection (c). Water curtain booths must provide a continuous sheet of water down the rear wall of the booth. For all water curtain booths, the owner or operator must visually monitor the water curtain during thermal spraying to ensure that the sheet is continuous without any gaps or dry spots. The owner or operator of a conventional water curtain booth must continuously monitor the water flow rate with a flow meter during thermal spraying to ensure the water flow meets or exceeds the minimum flow rate recommended by the manufacturer. The owner or operator of a pumpless water curtain booth must monitor the parameters recommended by the booth manufacturer to ensure that these parameters meet or exceed the manufacturer's recommendations. If the water curtain fails the continuity and/or flow requirements, the owner or operator must shut down the thermal spraying operation immediately to take corrective action. The thermal spraying operation must not be resumed until the monitored parameters meet or exceed the manufacturer's recommendations.
(4) Inspection and Maintenance Requirements
All thermal spraying operations with air pollution control systems must comply with the applicable inspection and maintenance requirements listed in Table 4.
Table 4 - Summary of Inspection and Maintenance Requirements for Thermal
Spraying Operations Using Add-on Air Pollution Control Devices


Control Inspection & Maintenance Requirements Frequen cy
Equipment
(A) Dry 1. Conduct a visual inspection to At least once
particulate ensure there are no leaks every 90 days.
filter
system
in accordance with Appendix 3.
(e.g., dry 2. Visually inspect ductwork from work At least once
filter area to the control device every 90 days.
cartridge,
HEPA filter) to ensure there are no leaks in
accordance with Appendix 3.
3. Replace filter. Per manufacturer's
specifications
or
permitting
agency's
requirement.

(B) Water Curtain 1. Visually inspect ductwork from booth At least once
to the exhaust stack to ensure every 90 days.
there are no leaks in accordance with
Appendix 3.
(C) All 1. Measure inward face velocity at each At least once per
opening in accordance with calendar year
and
Appendix 2. This requirement does not whenever the air
apply to existing thermal spraying pollution
control
operations that are remotely located system is changed
and comply with the standards in in any way that
may
section (c)(1)(E). impact air flow.



(5) Negative Pressure Measurements
Thermal spraying operations that are operating pursuant to subsection (c)(1)(B)5. (i.e., operating with the enclosure door open), must demonstrate negative pressure at least once every 12 months and whenever the enclosure is changed in any way that may impact air flow.
(f) Recordkeeping Requirements
(1) Monitoring Data Records
The owner or operator must maintain records of monitoring data required by subsection (e), including the date and time the data are collected. Recordkeeping logs must include the applicable acceptable limit(s) for: pressure drop (dry particulate control); water flow rate (conventional water curtain); or manufacturer's recommended parameter limits (pumpless water curtain).
(2) Inspection Records
The owner or operator must maintain inspection records that clearly document all inspections and maintenance activities to enable the permitting agency to determine whether the requirements of subsection (e)(4) have been met. The records may take the form of a checklist and must identify:
(A) the name of the device inspected;
(B) the date and time of inspection;
(C) a brief description of the working condition of the device during the inspection;
(D) all maintenance activities performed on the components of the air pollution control system (e.g., duct work replacement, filter replacement, fan replacement, leak repairs, etc.);
(E) the actions taken to correct deficiencies found during the inspection; and
(F) the person that conducted the inspection.
(3) Material Usage Records

For thermal spraying materials that contain chromium, chromium compounds, nickel, or nickel compounds, the owner or operator must record the name and quantity of material used during each month of the annual reporting period, and the total usage to date for that calendar year.
(4) Source Test Records
The owner or operator must maintain test reports documenting the conditions and results of all source tests.
(5) Equipment Malfunctions and Failures
The owner or operator must maintain records of the occurrence, duration, cause (if known), and action taken for each equipment malfunction and/or failure. This recordkeeping requirement applies only to equipment malfunctions or failures that cause or may cause uncontrolled emissions to be released.
(6) Records Maintenance and Retention
All records required by this subsection (f) must be readily accessible for inspection and review at the thermal spraying operation for at least five years. If so requested by the permitting agency, the owner or operator must provide copies of the records to the permitting agency.
(g) Reporting Requirements
(1) Initial Emission Inventory for Existing Thermal Spraying Operations
All existing thermal spraying operations must submit an emission inventory for hexavalent chromium and nickel to the permitting agency no later than October 1, 2005. This inventory must quantify the emissions from thermal spraying operations conducted during the 12-month period between July 1, 2004 and July 1, 2005. The emission inventory must be prepared in accordance with Appendix 1 or must be based on an emissions source test approved by the permitting agency.
(2) Annual Emission Inventory for Existing Thermal Spraying Operations Qualifying for the Standards for Remotely Located Operations or the Exemption for Operations with Low Emission Levels
Existing thermal spraying operations that qualify for the standards specified in subsection (c)(1)(E) or the exemption specified in subsection (c)(1)(F) must submit an annual report to the permitting agency by March 1st of each calendar year that quantifies emissions of hexavalent chromium and nickel from thermal spraying operations during the previous calendar year.
(3) Initial Notification
Existing thermal spraying operations that intend to begin using materials containing chromium, chromium compounds, nickel, or nickel compounds on or after January 1, 2005, must notify the permitting agency at least 45 days prior to using any of these materials. If the use of these materials begins before the operative date of this section, this notification may be delayed until the operative date of this section.
(4) Reports of Breakdowns, Equipment Malfunctions, and Failures
The owner or operator of a thermal spraying operation must report breakdowns, equipment malfunctions, and failures as required by the permitting agency. This reporting requirement only applies to equipment malfunctions or failures that cause or may cause uncontrolled emissions to be released.
(5) Source Test Documentation

(A) Notification of Source Test
The owner or operator of a thermal spraying operation must notify the permitting agency of his or her intention to conduct a source test to measure emissions of hexavalent chromium and/or nickel. The owner or operator must provide this notification to the permitting agency at least 60 days before the source test is scheduled. The notification must include a pre-test protocol and any other documentation required by the permitting agency.
(B) Reports of Source Test Results
The owner or operator of a thermal spraying operation must provide the source test results to the permitting agency no later than 60 days following completion of the testing.
(6) Adjustments to the Timeline for Submittal and Format of Reports
A permitting agency may change the timeline for submittal of periodic reports, allow consolidation of multiple reports into a single report, establish a common schedule for submittal of reports, or accept reports prepared to comply with other State or local requirements. Prior to allowing any of these changes, the permitting agency must determine that the change will provide the same information and will not reduce the overall frequency of reporting.
(h) Severability
Each part of this section is deemed severable, and in the event that any part of this section is held to be invalid, the remainder of this section shall continue in full force and effect.








Appendix 1 - Emission Calculation Method
Emissions of hexavalent chromium (Cr +6) and nickel (Ni) from thermal spraying operations must be calculated in accordance with the procedures specified in this Appendix 1.
Step 1: Identify all thermal spraying materials that contain chromium (Cr) or nickel (Ni) at a concentration of at least 0.1% by weight (or less than 0.1%, if listed on the Material Safety Data Sheet.) Include materials that contain chromium or nickel in the form of a metallic compound or alloy. Examples of compounds and alloys include, but are not limited to, stainless steel; chromium carbide (Cr 3 C 2); nichrome alloys (NiCr); and chromium oxide (Cr 2 O 3).
Step 2: Determine the total percentage of chromium and/or nickel contained in each thermal spraying material. These data can be obtained from the material safety data sheet (MSDS) or by contacting the manufacturer. If the MSDS contains a range of percentages, use the upper value of the range. If the material contains a compound (e .g., Cr 3 C 2), include only the portion that is chromium or nickel.
Step 3: For each thermal spraying operation, compile the annual usage for each thermal spraying material that contains chromium or nickel. For thermal spraying operations that have air permits, the annual usage is the maximum allowable under the permit.
Step 4: For each thermal spraying operation, calculate the annual usage quantities for chromium and nickel using the following equations:
Eqn. 1: [Annual Usage, lbs Cr/yr] = [Material Usage, lbs material used/yr]* [weight % Cr in Material]
Eqn. 2: [Annual Usage, lbs Ni/yr] = [Material Usage, lbs material used/yr]* [weight % Ni in Material]
Step 5. Identify the applicable emission factor(s) for each thermal spraying operation, based on the applicable control efficiency level. If a material is used for multiple thermal spraying operations and material usage records document the quantity of material used for each operation, use the applicable emission factors for each operation. If material usage records do not document the quantity of material used for each operation, use the highest emission factor.
Table 1-1 specifies the applicable emission factors for thermal spraying operations using materials that contain chromium, chromium compounds, or chromium alloys.
Table 1-2 specifies the applicable emission factors for thermal spraying operations using materials that contain nickel, nickel compounds, or nickel alloys.
Table 1-1: Thermal Spraying Emission Factors for Hexavalent Chromium

Emission Factors (lbs Cr+6/lb Cr sprayed)*


0% 90% 99% 99.97%
Operation Control Control Control Control
Efficiency Efficiency Efficiency Efficiency
(Uncontrolled) (e.g. Water (e.g. Dry (e.g., HEPA
Curtain) Filter) Filter)
Single-Wire 4.68E-03 4.68E-04 4.68E-05 1.40E-06

Flame Spray
Twin-Wire 6.96E-03 6.96E-04 6.96E-05 2.09E-06
Electric Arc
Spray
Flame Spray 6.20E-03 1.17E-03 6.20E-05 1.86E-06
HVOF 6.20E-03 1.17E-03 6.20E-05 1.86E-06
Plasma Spray 1.18E-02 6.73E-03 2.61E-03 2.86E-06
Other Thermal 7.17E-03 2.05E-03 5.70E-04 2.01E-06
Spraying


*Some emission factors are based directly on stack test results while others are calculated values, derived from stack test results and control efficiencies.
Table 1-2: Thermal Spraying Emission Factors for Nickel

Emission Factors (lbs Ni/lb Ni sprayed)*


0% 90% 99% 99.97%
Operation Control Control Control Control
Efficiency Efficiency Efficiency Efficiency
(Uncontrolled) (e.g. Water (e.g. Dry (e.g., HEPA
Curtain) Filter) Filter)
Twin-Wire 6.0E-03 6.0E-04 6.0E-05 1.8E-06
Electric Arc
Spray
Flame Spray 1.10E-01 4.64E-02 1.10E-03 3.30E-05
HVOF 1.10E-01 4.64E-02 1.10E-03 3.30E-05
Plasma Spray 1.5E-01 3.67E-02 1.5E-03 1.72E-05
Other Thermal 9.4E-02 3.25E-02 9.4E-04 2.13E-05

Spraying


*Some emission factors are based directly on stack test results while others are calculated values, derived from stack test results and control efficiencies.
Step 6 - Annual Emissions. For each thermal spraying operation, calculate the annual emissions by multiplying the applicable emission factors by the annual usage rates, using the following equations:
Eqn. 3: [Annual Emissions, lbs Cr +6/ yr] = [Emission Factor, lbs Cr +6/ lb Cr sprayed]*[Annual Usage, lbs Cr sprayed/yr]]
Eqn. 4: [Annual Emissions, lbs Ni/yr] = [Emission Factor, lbs Ni/lb Ni sprayed]*[Annual Usage, lbs Ni sprayed/yr]
Step 7 - Maximum Hourly Nickel Emissions: For each thermal spraying operation that uses nickel, calculate the maximum hourly emissions by multiplying the applicable emission factors by the maximum hourly usage rates, using the following equations:
Eqn. 5: [Max. Hourly Emissions, lbs Ni/hr] = [Emission Factor, lbs Ni/lb Ni sprayed]*[Max. Hourly Usage, lbs Ni sprayed/hr]
Eqn. 6: [Max. Hourly Usage, lbs Ni sprayed/hr] = [Max. Gun Spray Rate, lbs material sprayed/hr]*[Max. wt.% Ni in material]
where
"Maximum Gun Spray Rate" is the highest material throughput rate that a thermal spraying gun can achieve, based on manufacturer specifications or actual user experience, whichever is greater. If multiple guns have the potential to be operated at the same time (e.g., in two separate booths), the maximum gun spray rate must include the total throughput from all guns.
"Maximum Weight % Nickel in Material" is the highest weight percentage of nickel for all of the thermal spraying materials that are used in thermal spraying operations at a facility.
Point Source Example:

Thermal Spraying Inc. operates two thermal spraying booths. One booth is used for plasma spraying and the other booth is used for flame spraying and twin-wire electric arc spraying. Listed below is information on the facility's operations:

Booth Control Operation Materials Quantity % Total % Nickel
Device Used Used Chromium
Booth 1 HEPA Plasma Powder ABC 25 lbs/yr 25% 0%
Filter Spray
Powder XYZ 50 lbs/yr 20% 75%
Booth 2 Dry Flame Spray Powder 123 10 lbs/yr 0% 95%
Filter

(99% Powder XYZ 75 lbs/yr 20% 75%
effic.)
Twin-Wire Wire 1 80 lbs/yr 20% 5%


An example calculation is provided below for Thermal Spraying Inc.:
Step 1: Identify all thermal spraying materials that contain at least 0.1% by weight of chromium (Cr), chromium compounds, nickel (Ni), or nickel compounds.
The following four products contain chromium or nickel: Powder 123; Powder ABC; Powder XYZ; Wire #1.
Step 2: Determine the total percentage of chromium and/or nickel .

Materials Used % Total Chromium % Nickel
Powder 123 0% 95%
Powder ABC 25% 0%
Powder XYZ 20% 75%
Wire 1 20% 5%




If a thermal spraying material contains a compound, include only the portion that is chromium or nickel. For example, if the material contains 95% chromium oxide (Cr 2 O 3), the weight percent of chromium would be calculated as follows:
[Chromium Weight %]=[Weight % Cr2O3]*
[Molecular Weight of Chromium (Cr2)] /
[Molecular Weight of Chromium Oxide (Cr2O3)]
Molecular Weight of Chromium (Cr2) = (52 g/g-mol)*(2) = 104 g/g-mol Molecular Weight of Chromium Oxide (Cr2O3) = (52 g/g-mol)*(2)+(16)*(3) = 152 g/g-mol [Chromium Weight %]=[95 % Cr2O3]*
[104 g/g-mol] / [152 g/g-mol] =65%
Step 3: Compile the annual material usage.


Operation Materials Used Quantity Used
Plasma Spray Powder ABC 25 lbs/yr
Powder XYZ 50 lbs/yr
Flame Spray Powder 123 10 lbs/yr
Powder XYZ 75 lbs/yr
Twin-Wire Wire 1 80 lbs/yr


Step 4: Calculate the annual usage quantities for chromium and nickel.

Materials Quantity % Total % Nickel Qty. of Total Qty. of Nickel
Used Used Chromium Chromium Used Used
Powder ABC 25 lbs/yr 25% 0% [25 [25
lbs/yr]x[25% lbs/yr]x[ 0%
Cr] = Ni] =
6.25 lbs Cr/yr 0 lbs Ni/yr
Powder XYZ 50 lbs/yr 20% 75% [50 [50
lbs/yr]x[20% lbs/yr]x[75%

Cr] = Ni] =
10.0 lbs Cr/yr 37.5 lbs Ni/yr
Powder 123 10 lbs/yr 0% 95% [10 lbs/yr]x[0% [10 lbs/yr]x[9
Cr] = 5% Ni] =
0 lbs Cr/yr 9.5 lbs Ni/yr
Powder XYZ 75 lbs/yr 20% 75% [75 [75
lbs/yr]x[20% lbs/yr]x[75%
Cr] = Ni] =
15.0 lbs Cr/yr 56.25 lbs Ni/yr
Wire 1 80 lbs/yr 20% 5% [80 [80 lbs/yr]x[5
lbs/yr]x[20% % Ni] =
Cr] =
16.0 lbs Cr/yr 4.0 lbs Ni/yr


Step 5: Identify the applicable emission factors.

Emission Factor - Emission Factor -
Hexavalent Chromium Nickel
Control Device Operation (lb Cr+6/Cr sprayed) (lb Ni/lb Ni sprayed)
HEPA Filter Plasma Spray 2.86E-06 1.72E-05
Dry Filter Flame Spray 6.20E-05 1.10E-03
(99% effic.) Twin-Wire 6.96E-05 6.0E-05


Step 6: Calculate annual emissions ([Annual Emissions] = [Emission Factor]* [Annual Usage].)
For hexavalent chromium, the annual emissions are -

Qty. of Emission
Total Factor
Chromi- (lb Annual
um Cr+6/lb Emissions
Used
Booth Control Operation Materials (lbs Cr Cr (lb Cr+6/yr)
Device Used spra- sprayed)
yed/-
yr)
1 HEPA Plasma Powder ABC 6.25 2.86E-06 [6.25]x[2.86E-
Filter Spray -06] =
1.79E-05
Powder XYZ 10.0 2.86E-06 [10.0]x[2.86E-
-06] =
2.86E-05

2 Dry Flame Spray Powder 123 0 6.20E-05 [0]x[6.20E-05]
Filter = 0
(99% Powder XYZ 15.0 6.20E-05 [15.0]x[6.20E-
effic.) -05] =
9.30E-04
Twin-Wire Wire 1 16.0 6.96E-05 [16.0]x[6.96E-
-05] =
1.11E-03
Total = 0.002


Based on this emission level, Thermal Spraying Inc. is below the Tier 1 threshold for hexavalent chromium. Therefore, no new control efficiency requirements would be imposed by this ATCM because of hexavalent chromium emissions. However, Thermal Spraying Inc. will still need to comply with the permitting, monitoring, and recordkeeping requirements of the ATCM. In addition, if the workload increased and emissions exceeded Tier 1 thresholds, it would be necessary to upgrade the dry filter system or limit the usage of all chromium materials to the booth that has the HEPA filter.
For nickel, the annual emissions are -

Qty. of Emission Annual
Nickel Factor Emissions
Used
Booth Control Operation Materials (lbs Ni (lb Ni/lb (lb Ni/yr)
Device Used spray- Ni
ed/yr) sprayed)
1 HEPA Plasma Powder ABC 0 1.72E-05 [0]x[1.72E-0-
Filter Spray 5 ] =0
Powder XYZ 37.5 1.72E-05 [37.5]x[1.72-

E-05]
= 6.45E-04
2 Dry Flame Spray Powder 123 9.5 1.10E-03 [9.5]x[1.10E-
Filter 03]=
(99% 1.05E-02
effic.)
Powder XYZ 56.25 1.10E-03 [56.25]x[1.1-
0E-03]
= 6.19E-02
Twin-Wire Wire 1 4.0 6.0E-05 [4.0]x[6.0E--
05]=
2.40E-04
Total = 0.073


Based on this emission level, Thermal Spraying Inc. is below the Tier 1 threshold for nickel. Therefore, no new control efficiency requirements would be imposed by this ATCM because of nickel emissions. However, Thermal Spraying Inc. will still need to comply with the permitting, monitoring, and recordkeeping requirements of the ATCM. In addition, if the workload increased and emissions exceeded Tier 1 thresholds, it would be necessary to upgrade the dry filter system or limit the usage of all nickel materials to the booth that has the HEPA filter.
Step 7: Calculate the maximum hourly emissions for nickel. Powder 123 is the material that has the highest weight percentage of nickel (95%). The maximum spray rate for the flame spraying gun is 10 lbs/hr. The emission factor for flame spraying is 1.10E-03 lb Ni/lb Ni sprayed.
[Maximum Hourly Usage] = [Maximum Gun Spray Rate]*[Maximum Wt.% Nickel]
[Maximum Hourly Usage] = [10 lbs/hr]*[95% Ni] = 9.5 lbs Ni sprayed/hr
[Maximum Hourly Emissions] = [Emission Factor]*[Maximum Hourly Usage]
Maximum Hourly Emissions = [1.10E-03 lb Ni/lb Ni sprayed]*[9.5 lbs Ni sprayed/hr] = 0.01 lb Ni/hr
The maximum hourly emissions for nickel are 0.01 lbs Ni/hr, which is well below the compliance limit of 0.1 lb Ni/hr for point sources. Therefore, this thermal spraying operation complies with the maximum hourly limit for nickel.
Volume Source Example:

Machine Shop Inc. conducts flame spraying with powder on small parts. The parts are turned on a lathe while spraying is being performed. Since the lathe is not located in a booth, the shop uses a portable local exhaust fan to remove fumes from the worker's breathing area. This type of operation would be considered a volume source with 0% control efficiency. Listed below is information on the facility's operations:

Booth Control Operation Materials Quantity % Total %
Device Used Used Chromium Nickel
None None Flame Spray Powder 123 20 lbs/yr 0% 95%
(uncontrolled) Powder XYZ 5 lbs/yr 20% 75%



An example calculation is provided below for Machine Shop Inc.:
Step 1: Identify all thermal spraying materials that contain at least 0.1% by weight of chromium (Cr), chromium compounds, nickel (Ni), or nickel compounds.
The following two products contain chromium or nickel: Powder 123 and Powder XYZ.
Step 2: Determine the total percentage of chromium and/or nickel .

Materials Used % Total % Nickel
Chromium
Powder 123 0% 95%
Powder XYZ 20% 75%


Step 3: Compile the annual material usage.

Operation Materials Used Quantity Used

Flame Spray Powder 123 20 lbs/yr
Powder XYZ 5 lbs/yr


Step 4: Calculate the annual usage quantities for chromium and nickel.

Materials Quantity % Total % Qty. of Total
Used Used Chromium Ni- Chromium Used Qty. of Nickel Used
c
k
e
l
Powder 123 20 lbs/yr 0% 95% [20 lbs/yr]x[0% Cr] [20 lbs/yr]x[9 5%
= Ni] =
0 lbs Cr/yr 19.0 lbs Ni/yr
Powder XYZ 5 lbs/yr 20% 75% [5 lbs/yr]x[20% Cr] [5 lbs/yr]x[75 %
= Ni] =
1.0 lbs Cr/yr 3.75 lbs Ni/yr


Step 5: Identify the applicable emission factors.

Emission Factor -
Control Hexavalent Chromium Emission Factor - Nickel
Device Operation (lb Cr+6/lb Cr sprayed) (lb Ni/lb Ni sprayed)
Uncontrolled Flame Spray 6.20E-03 1.10E-01


Step 6: Calculate annual emissions ([Annual Emissions] = [Emission Factor]* [Annual Usage].)
For hexavalent chromium, the annual emissions are -

Qty. of
Total
Chromium Emission
Used Factor Annual
Control Materials (lbs Cr (lb Cr+6/lb Emissions
Cr
Booth Device Operation Used sprayed/- sprayed) (lb Cr+6/yr)
yr)
None None Flame Spray Powder 123 0 6.20E-03 [0]x[6.20E-03]
= 0
Powder XYZ 1.0 6.20E-03 [1.0]x[6.20E--
03]
= 6.20E-03
Total = 0.006



Based on this emission level, Machine Shop Inc. is classified as Tier 1 for hexavalent chromium. Therefore, the thermal spraying operation would need to install a new booth with a control device that met the Tier 1 minimum efficiency requirement of 99%. In addition, Machine Shop Inc. would need to comply with the permitting, monitoring, and recordkeeping requirements of the ATCM. Machine Shop Inc. could avoid having to install a new booth and control device, if they eliminated the use of chromium-containing materials.
For nickel, the annual emissions are -

Qty. of Emission
Nickels Factor Annual
Used
Control Materials (lbs Ni (lb Ni/lb Emissions
Ni
Booth Device Operation Used sprayed- sprayed) (lb Ni/yr)
/yr)
None None Flame Spray Powder 123 19.0 1.10E-01 [19.0]x[1.10E--
01 ]
= 2.09

Powder XYZ 3.75 1.10E-01 [3.75]x[1.10E--
01]
= 4.13E-01
Total = 2.50


Based on this emission level, Machine Shop Inc. is below the Tier 1 threshold for nickel. Therefore, no new control efficiency requirements would be imposed by this ATCM because of nickel emissions. However, this ATCM requires thermal spraying operations to comply with the most stringent control efficiency. Since the control efficiency requirement based on hexavalent chromium is the most stringent, they must comply with the 99% control efficiency.
Step 7: Calculate the maximum hourly emissions for nickel.
Powder 123 is the material that has the highest weight percentage of nickel (95%).
The maximum spray rate for the flame spraying gun is 10 lbs/hr.
The emission factor for flame spraying is 1.10E-01 lb Ni/lb Ni sprayed.
[Maximum Hourly Usage] = [Maximum Gun Spray Rate]*[Maximum Wt.% Nickel]
[Maximum Hourly Usage] = [10 lbs/hr]*[95 % Ni] = 9.5 lbs Ni sprayed/hr
[Maximum Hourly Emissions] = [Emission Factor]*[Maximum Hourly Usage]
Maximum Hourly Emissions = [1.10E-01 lb Ni/lb Ni sprayed]*[9.5 lbs Ni sprayed/hr] = 1.1 lb Ni/hr
The maximum hourly emissions for nickel are 1.1 lbs Ni/hr, which exceeds the compliance limit of 0.01 lb Ni/hr for volume sources. Therefore, this thermal spraying operation does not comply with the maximum hourly limit for nickel and it would be necessary to reduce emissions (e.g., install a control device, limit usage, etc.)








Appendix 2 - Method for Measuring Inward Face Velocity
Inward face velocity must be measured at least once every calendar year and whenever the air pollution control system is changed in any way that may impact air flow to ensure that the ventilation system is working properly. Measurements must be conducted in accordance with the procedures specified in this Appendix 2 or an alternative method approved by the permitting agency.
1. Hood Measurement:
Divide the face of the hood, the slot area, or the normal plane, at the capture velocity measurement point into equal area rectangles (see Figure 1). The side of each rectangular area should be no longer than 12 inches. Measure the air velocity (fpm) at the center of each rectangle using a calibrated anemometer or other measuring device approved by the permitting agency. The velocity measuring device must have an accuracy of at least +10% of full scale. The measuring device must be in good condition, of proper velocity range, and operated according to the manufacturer's instructions. The measuring device must be calibrated in accordance with the manufacturer's recommendations. Do not block or disturb the airflow while taking the readings.


Figure 1: Airflow distribution measurement for an exterior hood and an enclosing hood
Measure the volumetric airflow rate through the hood by measuring the velocity at the center of each equal-sized rectangular area (i.e., by performing pitot traverses.) If no suitable location exists for performing complete pitot traverses, measure the slot velocity and use this data to estimate the volumetric airflow rate through a hood.
2. Walk-in Booth Measurement:
For a cross-draft walk-in booth (i.e., air enters through filters in the front of the booth and leaves through filters in the back of the booth):
Divide the length of the booth into at least three cross-sectional areas to obtain the velocity profile in the booth. One cross-sectional area must be located near the exhaust plenum, one close to the supply plenum, and the other in the middle of the booth. Figure 2 illustrates the location of cross-sectional areas. Record the distance between each cross-sectional area and the exhaust or supply plenums. The distance between each cross-sectional area must not exceed ten feet.
Lay out imaginary grid lines through each cross sectional area. Use the intersections of the grid lines as locations to measure velocities inside the booth. The intersection points must be no more than six feet apart. Record the location of each point on the grid. Measure the air velocity (fpm) at each intersection point on the grid using a calibrated anemometer or other measuring device approved by the permitting agency. The velocity measuring device must have an accuracy of at least +10% of full scale. The measuring device must be in good condition, of proper velocity range, and operated according to the manufacturer's instructions. The measuring device must be calibrated in accordance with the manufacturer's recommendations.


Figure 2: Airflow distribution measurement inside a cross-draft walk-in booth
For a down-draft walk-in booth (i.e., air enters through filters in the ceiling of the booth and leaves through filters that cover trenches under a metal grate floor):
Divide the height of the booth into at least three cross-sectional areas to obtain the velocity profile in the booth. One cross-sectional area must be located near the exhaust plenum, one close to the supply plenum, and the other in the middle of the booth. Record the distance between each cross-sectional area and the exhaust or supply plenums. The distance between each cross-sectional area must not exceed ten feet.
Lay out imaginary grid lines through each cross sectional area. Use the intersections of the grid lines as locations to measure velocities inside the booth. The intersection points must be no more than six feet apart. Record the location of each point on the grid. Measure the air velocity (fpm) at each intersection point on the grid using a calibrated anemometer or other measuring device approved by the permitting agency. The velocity measuring device must have an accuracy of at least +10% of full scale. The measuring device must be in good condition, of proper velocity range, and operated according to the manufacturer's instructions. The measuring device must be calibrated in accordance with the manufacturer's recommendations.
3. Average Value of Readings
Calculate the average value for all velocity readings, if all individual readings are within +20% of the average value. Do not include turbulent readings when calculating the average (turbulent airflow may be indicated by negative or zero velocity readings.) Record and make available for inspection by the permitting agency the entire velocity profile to show the airflow distribution. Examples:
Hood A - Velocity Readings (fpm)


100 90 110
85 115 100
105 95 100
Average Velocity =
900 fpm / 9 =
100 fpm



Hood B - Velocity Readings (fpm)


200 200 0
200 50 0
100 -5 * -45 *
Average velocity =
750 fpm / 7 =
107 fpm **


* Negative values indicate airflow in reverse direction and are not included in the average.
** This is not a valid average, because individual readings are not within +20% of the average. The booth airflow needs to be adjusted and balanced before the velocity is measured again.








Appendix 3 - Leak Check Visual Inspection Checklist
Visual inspections must be conducted at least once every 90 days to ensure that no leaks are present in the control device or ventilation system. At a minimum, the inspection must include the items listed in the following checklist that are applicable. In addition to the items on this checklist, thermal spraying operations must inspect items in accordance with manufacturers' recommendations.




Note: Authority Cited: Sections 39600, 39601, 39650, 39658, 39659, 39666 and 41511, Health and Safety Code. Reference: Sections 39650, 39658, 39659, 39666 and 41511, Health and Safety Code.








s 93103. Regulation for Chromate Treated Cooling Towers.
(a) Definitions. In this regulation, hexavalent chromium and chromate are substances identified as toxic air contaminants by the Air Resources Board. You, yours, I, and my mean the person who owns or operates, or who plans to build, own, or operate, a cooling tower. The district is the local air pollution control district or air quality management district. A cooling tower is a device which evaporates circulating water to remove heat from a process, a building, or a refrigerator, and puts the heat into the ambient air. Must means a provision is mandatory, and may means a provision is permissive.
(b) Who must comply with this regulation? Any person who owns or operates, or who plans to build, own, or operate, a cooling tower must comply with this regulation.
(c) What must I do to comply with this regulation? To comply with this regulation, you must:
notify the district in writing about your cooling tower,
and
not add any hexavalent chromium-containing compounds to the cooling tower circulating water,
and
keep the hexavalent chromium concentration in the cooling tower circulating water less than 0.15 milligrams hexavalent chromium per liter of circulating water,
and

test the circulating water to determine the concentration of hexavalent chromium every six months,
and
keep the results of all required tests of circulating water for two years, and give them to the district when asked.
(d) What information must I send the district? Within 90 days after the effective date of this regulation, you must write and tell the district the following:
that you own or operate a cooling tower,
and
where the cooling tower is located,
and

who is the owner or operator of the cooling tower,
and
whether or not you use hexavalent chromium in the cooling tower,
and
if you are using hexavalent chromium, when you plan to stop.
(e) When must I comply with the hexavalent chromium limits? You must stop adding hexavalent chromium-containing compounds to the circulating water in your cooling tower and meet the 0.15 milligrams per liter hexavalent chromium concentration limit no later than 180 days after the effective date of the regulation. This is the compliance date for the regulation.
(f) For how long do I have to test the circulating water? If, after the effective date of this regulation, 2 consecutive required tests showing concentrations of hexavalent chromium less than 0.15 milligrams of hexavalent chromium per liter of circulating water, then the testing requirement is ended. All other requirements remain the same. The district may, however, require you to resume testing the circulating water at any time if the district has information that the circulating water may contain hexavalent chromium.
(g) How do I test the circulating water for hexavalent chromium? You must test the circulating water to determine hexavalent chromium concentrations using American Public Health Association Method 312B, or an equivalent method approved by the district. You will find Method 312B in a book called Standard Methods for the Examination of Water and Wastewater, Sixteenth Edition, published by the American Public Health Association, and available at libraries and bookstores nationwide.
(h) I use hexavalent chromium in a wooden cooling tower. Even if I stop adding hexavalent chromium on the compliance date, hexavalent chromium from the wood may cause the concentration in the circulating water to exceed 0.15 milligrams per liter for a time after the compliance date. How may I avoid being cited immediately after the compliance date? You may avoid being cited for violations of the 0.15 milligrams per liter hexavalent chromium concentration limit for up to six months after the compliance date. In order to not be cited during the transition period, you must:
comply with all other requirements of this regulation,

and
notify the district in writing that your cooling tower has wooden components that are exposed to the circulating water, and that you plan to take advantage of this section,
and
test the circulating water to determine the concentration of hexavalent chromium monthly
and
show a decrease in hexavalent chromium concentrations in the circulating water each month,
and
keep the results of the tests of circulating water for two years and give them to the district when asked,

and
the hexavalent chromium concentration in the circulating water must not exceed 8 milligrams hexavalent chromium per liter of circulating water.
(i) I am planning to build a cooling tower after the effective date of this regulation. Do I need to notify the district? Yes, no later than 90 days before you begin to operate the cooling tower, you must write and tell the district the following:
who is the owner and operator of the cooling tower,
and
where the cooling tower will be located,
and
when you plan to start operation.
(j) I switched to non-chromate treatments before this regulation became effective, do I have to meet the same requirements? If you have not used hexavalent chromium in your cooling tower for at least one year immediately before the compliance date, or if your cooling tower has never used hexavalent chromium, and you can demonstrate this to the district, then the district may waive the testing requirement. Such demonstration may be made by written certification signed by a company officer, that hexavalent chromium compounds have not been used within the year immediately before the compliance date. The district may, however, require you to test the circulating water at any time, if the district has information that the circulating water may contain hexavalent chromium.


Note: Authority cited: Section 39600, 39601, 39650 and 39666, Health and Safety Code. Reference: Sections 39650 and 39666, Health and Safety Code.








s 93104. Dioxins Airborne Toxic Control Measure -Medical Waste Incinerators.
(a) Definitions. For purposes of this section, the following definitions shall apply:
(1) "ARB" means the State of California Air Resources Board.
(2) "ARB Test Method 2" means the test method specified in title 17, California Code of Regulations, section 94102.
(3) "ARB Test Method 428" means the test method specified in title 17, California Code of Regulations, section 94139.
(4) "Control equipment" means any device which reduces emissions from medical waste incinerators.
(5) "Dioxins" means dibenzo-p-dioxins and dibenzofurans chlorinated in the 2, 3, 7, and 8 positions and containing 4, 5, 6, or 7 chlorine atoms and is expressed as 2, 3, 7, 8, tetrachlorinated dibenzo-para-dioxin equivalents using current California Department of Health Services toxic equivalency factors.
(6) "Facility" means every building, structure, appurtenance, installation, or improvement located on land which is under the same or common ownership or operation, and is on one or more contiguous or adjacent properties.
(7) "Medical facilities" means medical and dental offices, clinics and hospitals, skilled nursing facilities, research facilities, research laboratories, clinical laboratories, all unlicensed and licensed medical facilities, clinics and hospitals, surgery centers, diagnostic laboratories, and other providers of health care.
(8) "Medical waste incinerator" means all of the furnaces or other closed fire chambers that are located at a facility and used to dispose of waste generated at medical facilities by burning.
(9) "Uncontrolled emissions" means the dioxins emissions measured from the incinerator at a location downstream of the last combustion chamber, but prior to the air pollution control equipment.
(10) "Waste" means all discarded putrescible and nonputrescible solid, semisolid, and liquid materials, including garbage, trash, refuse, paper, rubbish, food, ashes, plastics, industrial wastes, demolition and construction wastes, equipment, instruments, utensils, appliances, manure, and human or animal solid and semisolid wastes.
(b) Requirements for medical waste incinerators that incinerate more than 25 tons of waste per year. The following requirements shall apply only to medical waste incinerators that incinerate more than 25 tons of waste per year:
(1) No person shall operate a medical waste incinerator unless:
(A) The dioxins emissions have been reduced by 99 percent or more of the uncontrolled emissions; or

(B) The dioxins emissions have been reduced to 10 nanograms or less per kilogram of waste burned.
(2) No person shall operate a medical waste incinerator unless the control equipment is installed and used in a manner which has been demonstrated to and approved by the district air pollution control officer to meet the following requirements:
(A) The flue gas temperature at the outlet of the control equipment shall not exceed 300 degrees Fahrenheit, unless it has been demonstrated to, and approved in writing by, both the ARB and the district air pollution control officer that lower emissions are achieved at a higher outlet temperature; and
(B) For a single chamber incinerator, the combustion chamber shall be maintained at no less than 1800 degrees (+ 200 degrees) Fahrenheit. For a multiple chamber incinerator, the primary combustion chamber shall be maintained at no less than 1400 degrees Fahrenheit, and the secondary chamber shall be maintained at no less than 1800 degrees (+ 200 degrees) Fahrenheit. The furnace design shall provide for a residence time for combustion gas of at least one second. Residence time shall be calculated using the following equation:
Residence Time = V
----
Qc)
where:
V means the volume, as expressed in cubic feet, from the point in the incinerator where the maximum temperature has been reached until the point where the temperature has dropped to 1600 degrees F.
Q c means the combustion gas flow through V, as expressed in actual cubic feet per second, which is determined with ARB Test Method 2 or calculated by the following equation:
Q c = Q stoi (1 + EA) (T c + 460) x ( 1 minute)
--- --------------- ------------
(100) (528) (60 seconds)
EA means the excess air, expressed as apercentage, supplied in excess of the air necessary to complete combustion.
T c means the maximum temperature, in degrees Fahrenheit, that has been reached in the incinerator.
Q stoi means the amount of air theoretically required for complete combustion, as expressed in standard cubic feet per minute (SCF) and calculated as follows:
(lb-mole O2) x (lb-waste) x (SCF O2) x (SCF air)
---------------- ---------- ------------ ---------
(lb-waste) (min) (lb-mole O2) (SCF O2)
(3) No person shall operate a medical waste incinerator unless the bottom ash, fly ash and scrubber residuals are handled and stored in a manner that prevents entrainment into ambient air.
(4) The owner or operator of a medical waste incinerator shall maintain the following:
(A) A continuous data recording system which provides for each day of operation continuous recording of the primary and secondary combustion chamber temperatures; carbon monoxide emissions; the key operating parameters of the air pollution control equipment, as specified by the district air pollution control officer; the hourly waste charging rates; and the opacity of stack emissions or other indicator of particulate matter which is approved by the district air pollution control officer;
(B) Maintenance records for the incinerator, control equipment, and monitoring equipment; and calibration records for the monitoring equipment; and
(C) Equipment for determining and recording the weight of waste charged to the incinerator.
(5) For purposes of demonstrating compliance with subsection (b)(1) of this rule the owner or operator of a medical waste incinerator shall conduct a minimum of two annual source-tests for the dioxins stack emissions using ARB Test Method 428, and a minimum of three sampling runs shall be conducted for the method. Annual source tests shall be conducted until at least two consecutive tests demonstrate compliance, at which time the frequency of future source tests is at the discretion of the Air Pollution Control Officer. For purposes of determining compliance with subsection (b)(1)(A) of this rule, emissions shall be sampled simultaneously from the flue at a location downstream of the last combustion chamber, but prior to the control equipment, and from the stack during source testing. For purposes of determining compliance with subsection (b)(1)(B) of this rule, the source testing shall be conducted at the stack. The information regarding the composition (moisture content, and amount of the total waste that is infectious, pathological, hazardous, or radioactive) and feed rate of the fuel charged during the source test shall be provided with the test results. The district air pollution control officer can require additional necessary information regarding the composition of the waste. Source testing shall be conducted at the maximum waste firing capacity (+-10 percent) allowed by the air district permit. A copy of all source test results conducted for purposes of demonstrating compliance with this rule shall be provided to the ARB at the same time that it is provided to the local air pollution control district.
(6) Any violation, malfunction, or upset condition on the incinerator, the air pollution control equipment, or the continuous data recording system shall be reported to the district within 1 hour of occurrence or by 9 a.m. the next business day if the malfunction occurs outside normal business hours and the district does not maintain a radio room or an answering machine. (continued)