### •
ILLINOIS ENVI"ONMENTAL PROTECTION AGENCY

P.o

.1.I0x19506, SPf UNGIl(tD, lwf\;QIS& 2794-95{)(, R[NEE CiPRIANO, DIR[CT OR 217/782-2113 LIFETHIE OPERATING PERl-lIT

- HARD CHROl-IE ELECTROPLATING OPERATION NESHAP SOURCE PERMITTEE Dover Industrial Attn: Ariel Schrodt 2929 North Campbell Chicago, Illinois 60618 Application No.: 73031729 Applicant'S Designation: Subject: Hard Chrome Plating Date Issued: October 19, 2004 Location: 2929 North Campbell, Chicago, 1.0. No .; 031600CUA Date Received: August 4, 2004 Expiration Date: See Condition 1

. 60618 This permit is hereby granted to the above-designated Permittee to OPERATE emission unitIs) and/or air pollution control equipment consisting of: Seven (7) Hard Chrome Electroplating Tanks Controlled by a Fume Suppressant One tl) Nickel Plating Tank pursuant to the above-referenced application. This permit is subject to standard conditions attached hereto and the following special condition(s); la. This permit shall expire 180 days after the Illinois EPA sends a

....'ritten request for the renewal of this permit. b. This permit shall terminate if it is withdrawn or is superseded by a revised permit. 2. This permit is issued based on negligible emissions of particulate matter (PM) from the nickel plating tank. For this purpose, emissions shall not exceed nominal rates of 0.1 lb/hr and 0.44 ton/yr. 3. This hard chrome electroplating facility is subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for chromium electroplating and anodizing, 40 eFR 63, Subparts A and N. The Illinois EPA is administering NESHAP in Illinois on behalf of the United States EPA under a delegation agreement. 4a. Air pollution control equipment associated with hard chrome electroplating tank(s) shall be operated at all times during the operation of the tanks. b. Chromium**deco~ating** using a fume suppressant containing a wetting agent shall not exceed the following limits pursuant to 40 CFR 63.342(d)(2): Equipment l'leasured With 7 Hard Chromium Plating Tank(s) Stalagometer Tensiometer

R

ooR. Bl/ \GOIEVICH,GOVERNOR PIllN1EDONRrCY CtH)l'AruI surface Tension (dynes/cm) 4S 35 

# /Page 2

c. Failure to operate in accordance with the operatingparameter value(s), determined during initialperformance testing, shall be considered a violation of the above limit, pursuant to 40 CFR 63, Subpart N. d. The Permittee shall be 

### in compliance with 40 CFR Part 63, Subpart N - National Emission Standard for decorative chromium plating immediately after startup.

e. This limit is the National Emission Standards for Chromium Emissions from Hard Chromium Electroplating Tanks, 40 CFR Part 63, Subpart Nand is based on the maximum cumulative potential rectifier capacity of the hard chrome electroplating tanks being greater than 60 million ampere-hours per year. An electroplating tank(s) installedbefore December 16, 1993, is considered an existing tank(s). Compliance with this limit shall be determined from initial performance testing and ongoing compliance monitoring requirements, as requiredby conditions in this permit. 5. The Permittee shall implement the following work practice standards for the hard chrome electroplating tanks, pursuant to 40 CFR 63.342(f):

a. At all times, includingperiods of startup, shutdown, and malfunction, the Permittee shall operate and maintain any affected source, including associated airpollution control devices and monitoring equipment, in a manner consistent with good air pollution control practices, consistent with the operation and maintenance plan. b. Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the operation and maintenanceplan.

c. Operation and maintenance requirements establishedpursuant to section 112 of the Act are enforceable independent of emissions limitations or other requirements 

### in relevant standards. d. Determination of whether acceptable operation andmaintenance procedures are being used will be based on information available to the Illinois EPA, which may include, but is not limited to, monitoring results; review of the operation and maintenance plan, procedures, and records; and inspection of the source. 6a. The Permittee shall implement the following Operation and Maintenance (0 &M) Plan, pursuant to 40 CFR 63.342(f)(3): 

### i. Description of the fume suppressant with wetting agent 

### inuse. 

### ii. Achecklist to document the operation and maintenance of the fume suppressant with wetting agent. iii. Procedure to follow to ensure that fume suppressant with wetting agent malfunctions due to poor maintenance or otherpreventable conditions do not occur.Page 3

iv. Procedure for identifying malfunctions and for implementing corrective actions.

v. The 0 &Mplan shall incorporate proposed workpractice standards. These proposed workpractice standards shall be submitted to the Illinois EPA for approval as part of the submittal required under 40 CFR 63.343(d). vi. The plan shall specifyprocedures to be followed to ensure that fume suppressant with wetting agent malfunctions due topoor maintenance or otherpreventable conditions do not occur. vii. The plan shall include a systematic procedure for identifying malfunctions of process equipment, add-on air pollution control devices (if any), and process and control systemmonitoring equipment and for implementing corrective actions to address such malfunctions. viii. If the operation and maintenance plan fails to address or inadequately addresses an event that meets the characteristics of a malfunction at the time the plan is initiallydeveloped, the Permittee shall revise the operation and maintenance plan within 45 days after such an event occurs. The revisedplan shall include procedures for operating and maintaining the process equipment, add-on airpollution control device, ormonitoring equipment during similarmalfunction events, and a program for corrective action for such events. ix. If actions taken by the Permittee during periods of malfunction are inconsistent with the procedures specified in the operation and maintenance plan, the Permittee shall record the actions taken for that event and shall report such actions within 2 working days after commencing actions inconsistent with the plan. This report shall be followed by a letter within 7 working days after the end of the vent, unless the Permittee makes alternative reporting arrangements, in advance, with the Illinois EPA.

x. The Permittee shall keep the written operation and maintenance plan on record after it is developed to be made available for inspection, upon request, by the Illinois EPA for the life of the affected source oruntil the source is no longer subject to the provisions of this subpart. In addition, if the operation andmaintenance plan is revised, the Permittee shall keep previous (i.e., superseded) versions of the operation and maintenance planon record to be made available for inspection, upon request, by the Illinois EPA for a period of 5 years after each revision to the plan. b. The Permitteemay use applicable standard operating procedure (SOP) manuals, Occupational Safety andHealthAdministration (OSHA) plans, provided the alternative plans meet the requirements of this section.Page 4

7a. The surface tension of the hard chromium electroplatingbaths using a fume suppressant containing a wetting agent shall not exceed 45 dynes per centimeter (measured with stalagometer) or 35 dynes/cm (measured with tensiometer), pursuant to 40 CFR 63.342(d)(2). This limit 

### is based on Maximum Achievable Control Technology (MACT) control performance standard for decorative chromium electroplating tanks. Compliance with this limit shall be determined from initial performance testing and ongoing compliance monitoring requirements, as requiredby conditions of this permit. b. The Permittee shall operate the fume suppressant/wetting agent at all times during the operation of decorative electroplating tanks. B. The Permittee of an affected source shall monitor the surface tension of the electroplating bath. Operation of the affected source at a surface tension greater than the value established during the performance test, or greater than 45 dynes/cm (measured with stalagometer) or 35 dynes/cm (measured with tensiometer) if the Permittee is using this value in accordance with 40 CFR 63.343(5)(i) shall constitute noncompliance with the standards. The surface tension shall be monitored according to the following schedule:

a. The surface tension shall be measured once every 4 hours during operation of the tank with stalagometer or a tensiometer as specified in Method 306B, Appendix Aof 40 CFR Part 63 Subpart N. b. The time between monitoring can be increased if there have been no exceedances. The surface tension shall be measured once every 4 hours of tank operation for the first 40 hours of tank operation after the compliance date. Once there are no exceedances during 40 hours of tank operation, surface tension measurement may be conducted once every 40 hours of tank operation on an ongoing basis, until an exceedance occurs. The minimum frequency of monitoring allowed by this subpart is once every 40 hours of tank operation.

c. Once exceedances occurs as indicated through surface tension monitoring, the original monitoring schedule of once every 4 hours must be resumed. Asubsequent decrease in frequency shall follow the schedule laid out above in condition 7(a). For example, if an Permittee had beenmonitoring an affected source once every 40 hours and an exceedance occurs, subsequent monitoring would take place once every 4 hours of tank operation. Once an exceedance does not occur for 40 hours of tank operation, monitoring can occuronce every 8 hours of tank operation. Once an exceedance does not occur for 40 hours of tank operationon this schedule, monitoring can occur once every 40 hours of tank operation. 9. The Permittee shall maintain records of the following items to demonstrate compliance with this permit.Page 5

a. The surface tension shall be monitored according to the following schedule: i. The surface tension shall be measured once every4 hours during operation of the tankwith a stalagometer or a tensiometer as specified in Method 306B, appendixAof 40 CFR 63 Subpart N. ii. The time betweenmonitoring can be increased if there have been no exceedances. The surface tension shall be measured once every 4 hours of tank operation for the first 40 hours of tank operation. Once there are no exceedances during 40 hours of tank operation, surface tension measurement may be conducted once every 8 hours of tank operation. Once there are no exceedances during 40 hours of tank operation, surface tension measurement may be conducted once every 40 hours of tank operation on an ongoing basis, until an exceedance occurs. The minimum frequency of monitoring allowed is once every 40 hours of tank operation. iii. Once an exceedance occurs as indicated through surface tension monitoring, the original monitoring schedule of once every 4 hours must be resumed. A subsequent decrease in frequency shall follow the schedule laid out in this permit. For example, if the Permittee hadbeenmonitoring an affected source once every 40 hours and an exceedance occurs, subsequent monitoring would take place once every 4 hours of tank operation. Once an exceedance does not occur for 40 hours of tank operation, monitoring can occur once every 8 hours of tank operation. Once an exceedance does not occur for 40 hours of tank operation on this schedule, monitoring can occur once every 40 hours of tank operation. iv. Once a bath solution is drained from the affected tank and a new solution added, the original monitoring schedule of once every 4 hours must be resumed, with a decrease in monitoring frequency allowed following the procedures in this permit. b. Records of all maintenance performed on the affected source, the fume suppressant wetting agent andmonitoring equipment.

c. Records of the occurrence, duration, and cause (if known) of each malfunction of process, fume suppressant wetting agent and monitoring equipment. d. Records of actions taken during periods of malfunctionwhen such actions are inconsistent with the operation andmaintenance plan.

e. Records, which may take the form of checklists, necessary to demonstrate consistencywith the operation andmaintenance plan requiredby 40 CFR 63.342(f)(3).Page 6

f. Test reports documenting results of all performance tests, if performance test were conducted. g. All measurements as may be necessary to determine the conditions of performance tests, including measurements necessary to determine compliance with the special complianceprocedures of 40 CFR 63.344(e). h. Records of monitoring data required by 40 CFR 63.343 that are used to demonstrate compliance with the standard including the date and time the data are collected. i. The specific identification (i.e., the date and time of commencement and completion) of each period of excess emissions, as indicated by monitoring data, that occurs duringmalfunction of the process, mist eliminator ormonitoring equipment. j. The specific identification (i.e., the date and time of commencement and completion) of eachperiod of excess emissions, as indicated bymonitoring data, that occurs during periods other than malfunction of the subject chrome plating tanks and associated control devices. k. The total process operating time of the affected chrome plating tank(s) during the reporting period. 1. Records of the date and time that fume suppressant wetting agents are added to the bath.

m. All documentation supporting the notifications and reports required by 40 CFR 63.9, 63.10 and 63.347.

n. All records shall be maintained for a period of five years, pursuant to 63.l0(b}(1). 10. The Permittee shall complywith the following reporting requirements, pursuant to 40 CFR 63.347:

a. The Permittee must submit initial notificationof construction/reconstruction to the Illinois EPA including the date of constructionor reconstruction within 30 calendar days after the commencement date. b. The initial notification shall contain the following: i. The name, title, and address of the Permittee. ii. The address (i.e., physical location) of each affected source. iii. Astatement that Subpart Nis the basis for this notification.Page 7

iv. Identificationof the applicable emission limitation and compliance date for each affected source.

v. Abrief description of each affected source, including the type of process operationperformed. vi. The maximum potential cumulative potential rectifier capacity. vii. Astatement of whether the affected source is located at a major source or an area source as defined in 40 CFR 63.2 of Subpart A. A. Anotification of the date when construction or reconstruction was commenced shall be submitted simultaneouslywith the notification of construction or reconstruction. B. Anotification of the date when construction or reconstruction was commenced shall be submitted no later than 30 calendar days of construction or reconstruction commencement date. C. Anotification of the actual date of startup of the source shall be submitted within 30 calendar days after such date. viii. The methods that will be used to determine continuous compliance. ix. Adescription of the air pollution control technique for each emission point.

x. A statement that the Permittee has completed and has on file the operation and maintenance plan as required by the workpractice standards of 40 CFR 63.342(f). xi. A. The Permittee shall demonstrate facility size based on using nonresettable ampere-hourmeters to measure actual cumulative rectifier capacity in accordance with 40 CFR 63.342(c)(2), and submit records to support that the facility is small. For existing sources, records from any 12-monthperiodpreceding the compliance date shall be used or a description of how operations will change to meet a small designation shall be provided. B. For new sources, records of projected rectifier capacity for the first 12-monthperiod of tank operation shall be used.Page 8

c. i. The Permittee shall notify the Illinois EPA in writing of intent to conduct a performance test (if conducted) at least 60 calendar days before the test is scheduled to begin to allow the Illinois EPA to have an observer present during the test, pursuant to 40 CFR 63.347(d). Observation of the performance test by the Illinois EPA is optional. ii. If the scheduled date for the test is changed for unforeseen reason, the Permittee shall inform the Illinois EPA within 5 calendar days of the originally schedule test date and must specify the date of the rescheduled test. d. The Permittee shall submit to the Illinois EPA a notification of compliance status, signed by the responsible official who shall certify its accuracy, attesting to whether the affected source has complied with this Subpart, pursuant to 40 CFR 63.347(e). The notification shall list the following: i. The applicable emission limitation and the methods that were used to determine compliance with this limitation. ii. The performance test report documenting the results of the performance test, which contains the elements required by 40 CFR 63.344(a), including measurements and calculations to support the special compliance provisions of 40 CFR 63.344(e) if these are being followed. iii. Records of projected rectifier capacity for the first 12- month period of tank operation shall be used. iv. A statement by the Permittee of the affected source as to whether the source has complied with the provisions of this Subpart.

v. The total duration of excess emissions (as indicated by the monitoring data) is 1 percent or greater of the total operating time for the reporting period; and vi. The total duration of malfunctions of the add-on air pollution control device and monitoring equipment is 5 percent or greater of the total operating time.

e. The notification of compliance status and reports of performance test results (if conducted) shall be submitted to the Illinois EPA no later than 90 calendar days following completion of the compliance demonstration/performance test. f. The Permittee shall prepare an ongoing compliance status report every year and retained on site, and made available to the Illinois EPA upon request. g. The ongoing compliance report shall contain the following:Page 9

i. The company name and address of the affected source. ii. An identification of the operatingparameter that is monitored for compliance determination. iii. The relevant emission limitation (i.e. surface tension in dynes/cm for the source, and the operating parametervalue, or range of values, that correspond to compliance with this emission limitation as specified in the notification of compliance status. iv. The beginning and ending dates of the reportingperiod.

v. Adescription of the type ofprocess performed 

### in the source. vi. The total operating time of the affected source during the reporting period. vii. Acertificationby a responsible official that the work practice standards followed in accordance with the operation and maintenance plan for the source. viii. If the operation and maintenance plan was not followed, an explanation of the reasons for not following the provisions, an assessment of whether anyparameter monitoring exceedances are believed to have occurred, and a copy of the report(s) documenting that the operation and maintenance plan was not followed. ix. Adescription of any changes inmonitoring processes, or controls since the last reporting period.

x. The name, title, and signature of the responsible official who is certifying the accuracy of the report. xi. The date of the report. xii. The actual cumulative rectifier capacityexpended during the reporting period, on a month-by-month basis, if the Permittee limits the maximum cumulative potential rectifier capacity less than 60 million amp-hr/yr. xiii. Asummary of operating parameter values, including the total duration of excess emissions during the reporting period as indicatedby those values, the total duration of excess emissions expressed as a percent of the total source operating time during that reporting period, and a breakdown of the total duration of excess emissions during the reporting period into those that are due toprocess upsets, control equipment malfunctions, other known causes, and unknown causes.Page 10

h. The Permittee shall report the results for eachmonitoring device. However, when one monitoring device is used as a backup for the primarymonitoring device, the Permittee shall only report the results from the monitoring device used to meet the monitoring requirements. If both devices are used to meet these requirements, then the Permittee shall report the results from eachmonitoring device for the relevant compliance period. 11. The Permittee shall maintain the following records:

a. Amount of material plated (tons/mo and tons/yr). 12. All records and logs required by this permit shall be retained at a readily accessible location at the source for at least three years from the date of entry and shall be made available for inspection and copying by the Illinois EPA upon request. Any records retained in an electronic format (e.g., computer) shall be capable of being retrieved and printed on paper during normal source office hours so as to be able to respond to an Illinois EPA request for records during the course of a source inspection. 13. If there is an exceedance of the requirements of this permit as determinedby the records required by this permit, the Permittee shall submit a report to the Illinois EPA's Compliance Section in Springfield, Illinois within 30 days after the exceedance. The report shall include the emissions released in accordance with the recordkeeping requirements, a copy of the relevant records, and a description of the exceedance orviolation and efforts to reduce emissions and future occurrences. 14. Two (2) copies of required reports and notifications concerning equipment operation or repairs, performance testing or a continuous monitoring system shall be sent to: Illinois Environmental ProtectionAgency Division of Air Pollution Control Compliance Section (#40) P.O. Box 19276 Springfield, Illinois 62794-9276 and one (1) copy shall be sent to the Illinois EPA's regional office at the following address unless otherwise indicated: Illinois Environmental ProtectionAgency Division of Air pollution Control 9511 West Harrison Des Plaines, Illinois 60016 15. Persons with lifetime operatingpermits must obtain a revisedpermit for anyof the following changes at the source:Page 11

a. An increase in emissions above the amount the emission unit or the source is permitted to emit; b. Amodification;

c. A change in operations that will result in the source's noncompliance with conditions in the existing permit; or d. A change in ownership, company name, or address, so that the application or existing permit is not longer accurate. Please note that the cold cleaning degreaser, coating operation and boiler is exempt, pursuant to 35 Ill. Adm. Code 201.146(v), (g) and (d), respectively. If you have any questions on this permit, please call Randy Solomon at 217/782-2113. 

# J)ts

Donald E. Sutton, P.E. Manager, Permit Section**DiViSi~~ r~~~~ution**  Control DES,RBS'psj

# ~ cc: Region 1 Illinois EPA, Compliance Section USEPA 

# COpy OriginalSigned

# by DonaldE.Sutton,

# P,E.STATE OF ILLINOIS ENVIRONMENTAL PROTECTION AGENCY DIVISION OF AIR POLLUTION CONTROL P.O. BOX 19506 SPRINGFIELD. ILLINOIS 62794-9506

STANDARD CONDITIONS FOR LIFBTIME OPBRATING PBRMXTS July 1, 1998 The· Illinois Environmental Protection Act [415 ILCS 5/39 (formerly Illinois Revised Statutes, Chapter 111-1/2, Section 1039») grants the Illinois Environmental Protection Agency authority to impose conditions on permits which it issues. 1. The issuance of this Permit does not release the Permittee from compliance with state and federal regulations which are part of the Illinois State Implementation Plan, as well as with other applicable statues and regulations of the United States or the State of Illinois or with applicable local laws, ordinances and regulations. 2. The Illinois EPA has issued this Permit based upon the information submitted by the Permittee in the permit application. Any misinformation, false statement or misrepresentation in the application shall be ground for revocation under 35 Ill. Adm. Code 201.166. 3.

4. a. The Permittee shall not authorize, cause, direct or allow any modification, as defined in 35 Ill. Adm. Code 201.102, of equipment, operations or practices which are reflected in the permit application as submitted, until the appropriate permit is obtained from the Illinois EPA. b. The Permittee shall obtain a new or revised permit under Section 39.5 of the Act, if the source no longer meets the applicability criteria of 35 Ill. Adm. Code 201169 because of changes in emissions units or control equipment.

c. The Permittee shall obtain a revised permit prior to any of the following changes at the source:

a. i. An increase in emissions above the amount the emission unit or the source is permitted to emit; or ii. Amodification; or iii. A change in operations that will result in the source's noncompliance with a condition in the existing permit; or iv. A change in ownership, company name, or address, application or existing permit is no longer accurate. so that the

This Permit only covers emission units and control equipment while physically present at the indicated source location. Unless the Permit specifically provides for equipment relocation, this Permit is void for n item of equipment on the day it is removed from the permitted location, or if all equipment is removed. b. The Permittee shall notify the Illinois EPA in writing to withdraw the Permit if all operations the source have been permanently discontinued.

Page 1 of 2 PRINTED ON RECYCLED PAPERCALCULATIONSHEET FACILITY:DoverIndustrialChrome DATERECEIVED:8/4/13 1.0.: 031600CUA ANALYSISENGINEER:RandySolomon DATE:8/13/4 P.N.:73031729 INTRODUCTION CompanyhasRegular OperatingPermitfor7HardChromeElectroplatingTankscontrolledbyfume suppressantandrecoverytunnelandisrequestingaLifetimePermittoreflecttheiroperationsasaSmall HardChromeFacilitywithallapplicableNESHAPconditions.ThefacilityislocatedinChicago,IL, regionI. FLAGS CASM,Keppner,OKtoissue ANALYSIS/RULES NSPS:N/A ColdCleaningSolventvp<ImmHg@68F,exempt,20U46v CoatingOperation« 5000gal/yr,exempt,201.146g Boiler<10mmbtu/hr,exempt,201.146 NickelPlating NegligiblePM 7HardChromeTankssubjecttoCAAPP,pursuanttoNESHAP,SubpartN,40CFR63.J40e2 DeferraltoobtainaCAAPPPermithasbeenextendedanother5years . 7HardChromeTankssubjecttoNationalEmissionStandardsforHazardousAirPollutants (NESHAP),SubpartsA& N: InitialNotification, incompliancewith40CFR63.J47c NotificationofConstructionincompliancewith40CFR63.J45b NotificationofCompliance,incompliance,pursuantto40CFR63.347e PerformanceTestResultsareincompliancefor6tanks,pursuantto40CFR 63.344,7tlttanknottestedbecauseonly6tanksusedatanyonetime.Dixon Nwajiacceptsthisbecausetheyareusingfumesuppressant. RECOMMENDATIONS/CONCLUSIONS GrantLifetimeOperatingPermit