• 

ILLI NOIS ENVI"ONMENTAL P ROTECTION AGENCY 

P.o. 1.I0 x 19506, SPfUNGIl(tD, lwf\;QIS &2794-95{)(, 

R[NEE CiPRIANO, D IR[CTOR 

217 / 782 -2 113 

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 Pla t ing 

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 unit Is ) and / or air pollution control equ i pment consisting of: 

Seven (7) Hard Chrome Electroplating Tanks Co ntrolled by a Fume Suppressant 

One t l) Nicke l Plating Tank 

pursuant to the above-referenced application. This permit is subject to 

standard c o nditions 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b. This permit shall terminate if it is withdrawn or is superseded by a 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 

Roo R. Bl/\ GOIEVICH, GOVERNOR 

PIllN1ED ON RrCYCtH) l'AruI 

surface Tension 

(dynes/cm) 

4S 

35 

/ 
Page 2 

c. Failure to operate in accordance with the operating parameter value(s), 

determined during initial performance 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) installed before 

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 required by 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, including periods of startup, shutdown, and 

malfunction, the Permittee shall operate and maintain any 

affected source, including associated air pollution 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 maintenance plan. 

c. Operation and maintenance requirements established pursuant to 

section 112 of the Act are enforceable independent of emissions 

limitations or other requirements in relevant standards. 

d. Determination of whether acceptable operation and maintenance 

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 in use. 

ii. A checklist 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 other preventable 

conditions do not occur. 
Page 3 

iv. Procedure for identifying malfunctions and for implementing 

corrective actions. 

v. The 0 & M plan shall incorporate proposed work practice 

standards. These proposed work practice 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 specify procedures to be followed to ensure that 

fume suppressant with wetting agent malfunctions due to poor 

maintenance or other preventable 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 system monitoring 

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 initially developed, the 

Permittee shall revise the operation and maintenance plan within 

45 days after such an event occurs. The revised plan shall 

include procedures for operating and maintaining the process 

equipment, add-on air pollution control device, or monitoring 

equipment during similar malfunction 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 or until the source is no longer subject to the provisions of 

this subpart. In addition, if the operation and maintenance plan is 

revised, the Permittee shall keep previous (i.e., superseded) 

versions of the operation and maintenance plan on 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 Permittee may use applicable standard operating procedure (SOP) 

manuals, Occupational Safety and Health Administration (OSHA) plans, 

provided the alternative plans meet the requirements of this section. 
Page 4 

7a. The surface tension of the hard chromium electroplating baths 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 required by 

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 A of 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. A subsequent decrease in frequency shall 

follow the schedule laid out above in condition 7(a). For 

example, if an Permittee had been monitoring 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. 

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 every 4 hours 

during operation of the tank with a stalagometer or a 

tensiometer as specified in Method 306B, appendix A of 40 

CFR 63 Subpart N. 

ii. 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. 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 had been monitoring 

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 and monitoring 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 malfunction when such 

actions are inconsistent with the operation and maintenance plan. 

e. Records, which may take the form of checklists, necessary to 

demonstrate consistency with the operation and maintenance plan 

required by 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 compliance procedures 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 during malfunction 

of the process, mist eliminator or monitoring equipment. 

j. 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 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 comply with the following reporting requirements, 

pursuant to 40 CFR 63.347: 

a. The Permittee must submit initial notification of 

construction/reconstruction to the Illinois EPA including the 

date of construction or 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. A statement that Subpart N is the basis for this 

notification. 
Page 7 

iv. Identification of the applicable emission limitation and 

compliance date for each affected source. 

v. A brief description of each affected source, including the 

type of process operation performed. 

vi. The maximum potential cumulative potential rectifier 

capacity. 

vii. A statement 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. A notification of the date when construction or 

reconstruction was commenced shall be submitted 

simultaneously with the notification of construction 

or reconstruction. 

B. A notification 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. A notification 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. A description 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 

work practice standards of 40 CFR 63.342(f). 

xi. A. The Permittee shall demonstrate facility size based 

on using nonresettable ampere-hour meters 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-month period preceding 

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-month period 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 operating parameter that is 

monitored for compliance determination. 

iii. The relevant emission limitation (i.e. surface tension in 

dynes/cm for the source, and the operating parameter value, 

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 reporting period. 

v. A description of the type of process performed in the source. 

vi. The total operating time of the affected source during the 

reporting period. 

vii. A certification by 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 any parameter 

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. A description of any changes in monitoring 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 capacity expended 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. A summary of operating parameter values, including the 

total duration of excess emissions during the reporting 

period as indicated by 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 to process 

upsets, control equipment malfunctions, other known causes, 

and unknown causes. 
Page 10 

h. The Permittee shall report the results for each monitoring 

device. However, when one monitoring device is used as a backup 

for the primary monitoring 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 

each monitoring 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 

determined by 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 or violation 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 Protection Agency 

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 Protection Agency 

Division of Air pollution Control 

9511 West Harrison 

Des Plaines, Illinois 60016 

15. Persons with lifetime operating permits must obtain a revised permit 

for any of 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. A modification; 

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 

Original Signed by 

Donald E. 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. A modification; 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 PAPER 
CALCULATION SHEET 

FACILITY: Dover Industrial Chrome DATE RECEIVED: 8/4/13 

1.0.: 031600CUA ANALYSIS ENGINEER: Randy Solomon 

DATE: 8/13/4 P.N.: 73031729 

INTRODUCTION 

Company has Regular Operating Permit for 7 Hard Chrome Electroplating Tanks controlled by fume 

suppressant and recovery tunnel and is requesting a Lifetime Permit to reflect their operations as a Small 

Hard Chrome Facility with all applicable NESHAP conditions. The facility is located in Chicago, IL, 

region I. 

FLAGS 

CASM, Keppner, OK to issue 

ANALYSIS/RULES 

NSPS:N/A 

Cold Cleaning Solvent vp < I mmHg@68F, exempt, 20U46v 

Coating Operation « 5000 gal/yr, exempt, 201.146g 

Boiler < 10 mmbtu/hr, exempt, 201.146 

Nickel Plating 

Negligible PM 

7 Hard Chrome Tanks subject to CAAPP, pursuant to NESHAP, Subpart N, 40 CFR 63.J40e2 

Deferral to obtain a CAAPP Permit has been extended another 5 years . 

7 Hard Chrome Tanks subject to National Emission Standards for Hazardous Air Pollutants 

(NESHAP), Subparts A & N: 

Initial Notification, in compliance with 40 CFR 63.J47c 

Notification of Construction in compliance with 40 CFR 63.J45b 

Notification of Compliance, in compliance, pursuant to 40 CFR 63.347e 

Performance Test Results are in compliance for 6 tanks, pursuant to 40 CFR 

63.344, 7tlt tank not tested because only 6 tanks used at anyone time. Dixon 

Nwaji accepts this because they are using fume suppressant. 

RECOMMENDATIONS/CONCLUSIONS 

Grant Lifetime Operating Permit