CONSTRUCTION and MINOR SOURCE OPERATING

PERMIT

OFFICE OF AIR MANAGEMENT

Cope Brothers Machine Shop

5301 E SR 231

 Leroy, IN 46355

(herein known as the Permittee) is hereby authorized to operate subject to the conditions

contained herein, the emission units described in Section A (Source Summary) of this permit. 

This permit is issued to the above mentioned company under the provisions of 326 IAC 2-1.1,

326 IAC 2-6.1 and 40 CFR 52.780, with conditions listed on the attached pages.

 

Operation Permit No.: MSOP 089-11760-00452

Issued by: 

Paul Dubenetzky, Branch Chief

Office of Air Management

Issuance Date:
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 2 of 26

TABLE OF CONTENTS

A SOURCE SUMMARY

A.1 General Information [326 IAC 2-5.1-3(c)] [326 IAC 2-6.1-4(a)]

A.2 Emission Units and Pollution Control Equipment Summary 

A.3 Part 70 Permit Applicability [326 IAC 2-7-2]

B GENERAL CONSTRUCTION CONDITIONS

B.1 Permit No Defense [IC 13]

B.2 Definitions 

B.3 Effective Date of the Permit [IC13-15-5-3]

B.4 Revocation of Permits [326 IAC 2-1.1-9(5)]

B.5 Modification to Permit [326 IAC 2]

B.6 Minor Source Operating Permit [326 IAC 2-6.1]

C SOURCE OPERATION CONDITIONS

C.1 PSD Minor Source Status [326 IAC 2-2] [40 CFR 52.21] 

C.2 Preventive Maintenance Plan [326 IAC 1-6-3]

C.3 Permit Revision [326 IAC 2-5.1-3(e)(3)] [326 IAC 2-6.1-6]

C.4 Inspection and Entry [326 IAC 2-7-6(2)]

C.5 Transfer of Ownership or Operation [326 IAC 2-6.1-6(d)(3)]

C.6 Permit Revocation [326 IAC 2-1-9]

C.7 Opacity [326 IAC 5-1]

Testing Requirements

C.8 Performance Testing [326 IAC 3-6][326 IAC 2-1.1-11]

Compliance Monitoring Requirements 

C.9 Monitoring Methods [326 IAC 3]

C.10 Actions Related to Noncompliance Demonstrated by a Stack Test

Record Keeping and Reporting Requirements

C.11 Malfunctions Report [326 IAC 1-6-2]

C.12 Monitoring Data Availability [326 IAC 2-6.1-2] [IC 13-14-1-13]

C.13 General Record Keeping Requirements [326 IAC 2-6.1-2]

C.14 General Reporting Requirements [326 IAC 2-1.1-11] [326 IAC 2-6.1-2] [IC 13-14-1-13] 

C.15 Annual Notification [326 IAC 2-6.1-5(a)(5)] 

D.1 Emissions unit OPERATION CONDITIONS - Hard chromium electroplating operation

Emission Limitations and Standards 

D.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR Part 63, Subpart A]

D.1.2 Chromium Electroplating NESHAP [326 IAC 20-8-1] [40 CFR Part 63, Subpart N]

D.1.3 Chromium Emissions Limitation [40 CFR 63.342(c)] [40 CFR 63.343(a)(1)&(2)]

D.1.4 Work Practice Standards [40 CFR 63.342(f)]
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 3 of 26

Compliance Determination Requirements [326 IAC 2-1.1-11]

D.1.5 Preventive Maintenance Plan [326 IAC 1-6-3]

D.1.6 Operation and Maintenance Plan [40 CFR 63.342(f)(3)]

D.1.7 Performance Testing [326 IAC 2-1.1-11] [40 CFR 63.343(b)(2)] [40 CFR 63.7]

Compliance Monitoring Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2) ]

D.1.8 Monitoring to Demonstrate Continuous Compliance [326 IAC 2-6.1-5(a)(2)]

D.1.9 Record Keeping Requirements [40 CFR 63.346]

D.1.10 Reporting Requirements [326 IAC 3-6-4(b)] [40 CFR 63.344(a), 63.345 and 63.347]

Annual Notification

Ongoing Compliance Status Report

Malfunction Report
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 4 of 26

SECTION A SOURCE SUMMARY

This permit is based on information requested by the Indiana Department of Environmental Management

(IDEM), Office of Air Management (OAM). The information describing the source contained in conditions

A.1 through A.3 is descriptive information and does not constitute enforceable conditions. However, the

Permittee should be aware that a physical change or a change in the method of operation that may

render this descriptive information obsolete or inaccurate may trigger requirements for the Permittee to

obtain additional permits or seek modification of this permit pursuant to 326 IAC 2, or change other

applicable requirements presented in the permit application.

A.1 General Information [326 IAC 2-5.1-3(c)] [326 IAC 2-6.1-4(a)] 

The Permittee owns and operates a stationary hard chromium electroplating operation.

Authorized Individual: Larry Cope

Source Address: 5301 E SR 231, Leroy, IN 46355

Mailing Address: 5301 E SR 231, Leroy, IN 46355

Phone Number: 219-663-5661

SIC Code: 3471

County Location: Lake

County Status: Nonattainment for Ozone

Attainment area for all other criteria pollutants

Source Status: Minor Source Operating Permit

Minor Source, under PSD Rules; 

Minor Source, Section 112 of the Clean Air Act

A.2 Emissions units and Pollution Control Equipment Summary 

This stationary source is approved to operate the following emissions units and pollution control

devices:

(a) One (1) hard chromium electroplating operation, identified as HC-1, using a composite

mesh-pad system for control, having a rectifier with a maximum potential capacity of

5,000 amperes and exhausting to one (1) stack identified as S1; and

(b) One (1) hard chromium electroplating operation, identified as HC-2, using a composite

mesh-pad system for control, having a rectifier with a maximum potential capacity of

5,000 amperes and exhausting to one (1) stack identified as S1.

(c) One (1) hot water boiler, with a maximum rated heat input of 0.150 mmBtu of natural gas.

(d) Two (2) space heaters, each with a maximum rated heat input of 0.175 mmBtu of natural

gas.

A.3 Part 70 Permit Applicability [326 IAC 2-7-2]

This stationary source is not required to have a Part 70 permit by 326 IAC 2-7-2 (Applicability)

because:

(a) It is a minor source, as defined in 326 IAC 2-7-1(22);

(b) It is not an affected source under Title IV (Acid Deposition Control) of the Clean Air Act,

as defined in 326 IAC 2-7-1(3);

(c) It is not in a source in a source category designated by the United States Environmental

Protection Agency (U.S. EPA) under 40 CFR 70.3 (Part 70 - Applicability).
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 5 of 26

SECTION B GENERAL CONSTRUCTION CONDITIONS

THIS SECTION OF THE PERMIT IS BEING ISSUED UNDER THE PROVISIONS OF 326 IAC 2-1.1 AND

40 CFR 52.780, WITH CONDITIONS LISTED BELOW.

B.1 Permit No Defense [IC 13]

This permit to construct does not relieve the Permittee of the responsibility to comply with the

provisions of the Indiana Environmental Management Law (IC 13-11 through 13-20; 13-22

through 13-25; and 13-30), the Air Pollution Control Law (IC 13-17) and the rules promulgated

thereunder, as well as other applicable local, state, and federal requirements.

B.2 Definitions

Terms in this permit shall have the definition assigned to such terms in the referenced

regulation. In the absence of definitions in the referenced regulation, any applicable definitions

found in IC 13-11, 326 IAC 1-2, and 326 IAC 2-1.1-1 shall prevail.

B.3 Effective Date of the Permit [IC13-15-5-3]

Pursuant to IC 13-15-5-3, this permit becomes effective upon its issuance.

B.4 Revocation of Permits [326 IAC 2-1.1-9(5)]

Pursuant to 326 IAC 2-1.1-9(5)(Revocation of Permits), the Commissioner may revoke this

permit if construction is not commenced within eighteen (18) months after receipt of this

approval or if construction is suspended for a continuous period of one (1) year or more.

B.5 Modification to Permit [326 IAC 2]

Notwithstanding the Section B condition entitled “Minor Source Operating Permit”, all

requirements and conditions of this construction permit shall remain in effect unless modified in

a manner consistent with procedures established for modifications of construction permits

pursuant to 326 IAC 2 (Permit Review Rules).

B.6 Minor Source Operating Permit [326 IAC 2-6.1]

This document shall also become a minor source operating permit pursuant to 326 IAC 2-6.1 

when, prior to start of operation, the following requirements are met:

(a) The attached Affidavit of Construction shall be submitted to the Office of Air

Management (OAM), Permit Administration & Development Section.

(1) If the Affidavit of Construction verifies that the facilities covered in this

Construction Permit were constructed as proposed in the application, then the

facilities may begin operating on the date the Affidavit of Construction is

postmarked or hand delivered to IDEM.

(2) If the Affidavit of Construction does not verify that the facilities covered in this

Construction Permit were constructed as proposed in the application, then the

Permittee shall receive an Operation Permit Validation Letter from the Chief of

the Permit Administration & Development Section prior to beginning operation of

the facilities.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 6 of 26

(b) If construction is completed in phases; i.e., the entire construction is not done

continuously, a separate affidavit must be submitted for each phase of construction. 

Any permit conditions associated with operation start up dates such as stack testing for

New Source Performance Standards (NSPS) shall be applicable to each individual

phase. 

(c) Upon receipt of the Operation Permit Validation Letter from the Chief of the Permit

Administration & Development Section, the Permittee shall attach it to this document.

(d) The operation permit will be subject to annual operating permit fees pursuant to 326 IAC

2-1.1-7(Fees).

(e) Pursuant to 326 IAC 2-6.1-7, the Permittee shall apply for an operation permit renewal at

least ninety (90) days prior to the expiration date established in the validation letter. If

IDEM, OAM, upon receiving a timely and complete permit application, fails to issue or

deny the permit renewal prior to the expiration date of this permit, this existing permit

shall not expire and all terms and conditions shall continue in effect until the renewal

permit has been issued or denied. The operation permit issued shall contain as a

minimum the conditions in Section C and Section D of this permit. 
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 7 of 26

SECTION C SOURCE OPERATION CONDITIONS

Entire Source

C.1 PSD Minor Source Status [326 IAC 2-2] [40 CFR 52.21] 

(a) The total source potential to emit of all criteria pollutants is less than 250 tons per year. 

Therefore the requirements of 326 IAC 2-2 (Prevention of Significant Deterioration) and

40 CFR 52.21 will not apply.

(b) Any change or modification which may increase potential to emit to 250 tons per year

from this source, shall cause this source to be considered a major source under PSD,

326 IAC 2-2 and 40 CFR 52.21, and shall require approval from IDEM, OAM prior to

making the change.

(b) Any change or modification which may increase potential to emit of VOC or NOX to 25

tons per year or increase potential to emit of any other criteria pollutant to 100 tons per

year from this source, shall cause this source to be considered a major source under

Emission Offset, 326 IAC 2-3, and shall require approval from IDEM, OAM prior to

making the change.

C.2 Preventive Maintenance Plan [326 IAC 1-6-3]

(a) If required by specific condition(s) in Section D of this permit, the Permittee shall prepare

and maintain Preventive Maintenance Plans (PMP) after issuance of this permit, including

the following information on each emissions unit:

(1) Identification of the individual(s) responsible for inspecting, maintaining, and

repairing emission control devices;

(2) A description of the items or conditions that will be inspected and the inspection

schedule for said items or conditions; 

(3) Identification and quantification of the replacement parts that will be maintained in

inventory for quick replacement.

(b) The Permittee shall implement the Preventive Maintenance Plans as necessary to

ensure that failure to implement the Preventive Maintenance Plan does not cause or

contribute to a violation of any limitation on emissions or potential to emit.

(c) PMP’s shall be submitted to IDEM, OAM, upon request and shall be subject to review

and approval by IDEM, OAM,. IDEM, OAM, may require the Permittee to revise its

Preventive Maintenance Plan whenever lack of proper maintenance causes or

contributes to any violation.

C.3 Permit Revision [326 IAC 2-5.1-3(e)(3)] [326 IAC 2-6.1-6]

(a) The Permittee must comply with the requirements of 326 IAC 2-6.1-6 whenever the

Permittee seeks to amend or modify this permit. 
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 8 of 26

(b) Any application requesting an amendment or modification of this permit shall be

submitted to:

Indiana Department of Environmental Management

Permits Branch, Office of Air Management

100 North Senate Avenue, P.O. Box 6015 

Indianapolis, Indiana 46206-6015

Any such application should be certified by the “authorized individual” as defined by 

326 IAC 2-1.1-1. 

(c) The Permittee shall notify the OAM within thirty (30) calendar days of implementing a

notice-only change. [326 IAC 2-6.1-6(d)]

C.4 Inspection and Entry [326 IAC 2-7-6(2)]

Upon presentation of proper identification cards, credentials, and other documents as may be

required by law, and subject to the Permittee’s right under all applicable laws and regulations to

assert that the information collected by the agency is confidential and entitled to be treated as

such, the Permittee shall allow IDEM, OAM, U.S. EPA, or an authorized representative to

perform the following:

(a) Enter upon the Permittee's premises where a permitted source is located, or

emissions related activity is conducted, or where records must be kept under the

conditions of this permit;

(b) Have access to and copy, at reasonable times, any records that must be kept under this

title or the conditions of this permit or any operating permit revisions;

(c) Inspect, at reasonable times, any processes, emissions units (including monitoring and air

pollution control equipment), practices, or operations regulated or required under this

permit or any operating permit revisions; 

(d) Sample or monitor, at reasonable times, substances or parameters for the purpose of

assuring compliance with this permit or applicable requirements; and

(e) Utilize any photographic, recording, testing, monitoring, or other equipment for the

purpose of assuring compliance with this permit or applicable requirements.

C.5 Transfer of Ownership or Operation [326 IAC 2-6.1-6(d)(3)]

Pursuant to [326 IAC 2-6.1-6(d)(3)] :

(a) In the event that ownership of this source is changed, the Permittee shall notify IDEM,

OAM, Permits Branch, within thirty (30) days of the change. 

(b) The written notification shall be sufficient to transfer the permit to the new owner by an

notice-only change pursuant to 326 IAC 2-6.1-6(d)(3). 

(c) IDEM, OAM, shall issue a revised permit.

The notification which shall be submitted by the Permittee does require the certification by the

“authorized individual” as defined by 326 IAC 2-1.1-1.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 9 of 26

C.6 Permit Revocation [326 IAC 2-1-9]

Pursuant to 326 IAC 2-1-9(a)(Revocation of Permits), this permit to construct and operate may

be revoked for any of the following causes:

(a) Violation of any conditions of this permit.

(b) Failure to disclose all the relevant facts, or misrepresentation in obtaining this permit.

(c) Changes in regulatory requirements that mandate either a temporary or permanent

reduction of discharge of contaminants. However, the amendment of appropriate

sections of this permit shall not require revocation of this permit.

(d) Noncompliance with orders issued pursuant to 326 IAC 1-5 (Episode Alert Levels) to

reduce emissions during an air pollution episode.

(e) For any cause which establishes in the judgment of IDEM the fact that continuance of

this permit is not consistent with purposes of this article.

C.7 Opacity [326 IAC 5-1]

Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3

(Temporary Alternative Opacity Limitations), opacity shall meet the following, unless otherwise

stated in this permit:

(a) Opacity shall not exceed an average of twenty percent (20%) in any one (1) six (6)

minute averaging period as determined in 326 IAC 5-1-4.

(b) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen

(15) minutes (sixty (60) readings) as measured according to 40 CFR 60, Appendix A,

Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a

continuous opacity monitor in a six (6) hour period.

Testing Requirements

C.8 Performance Testing [326 IAC 3-6][326 IAC 2-1.1-11]

(a) Compliance testing on new emissions units shall be conducted within 60 days after

achieving maximum production rate, but no later than 180 days after initial start-up, if

specified in Section D of this approval. All testing shall be performed according to the

provisions of 326 IAC 3-6 (Source Sampling Procedures), except as provided elsewhere

in this permit, utilizing any applicable procedures and analysis methods specified in 40

CFR 51, 40 CFR 60, 40 CFR 61, 40 CFR 63, 40 CFR 75, or other procedures approved

by IDEM, OAM.

A test protocol, except as provided elsewhere in this permit, shall be submitted to:

Indiana Department of Environmental Management

Compliance Data Section, Office of Air Management

100 North Senate Avenue, P. O. Box 6015

Indianapolis, Indiana 46206-6015
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 10 of 26

no later than thirty-five (35) days prior to the intended test date. The Permittee shall

submit a notice of the actual test date to the above address so that it is received at least

two weeks prior to the test date.

(b) All test reports must be received by IDEM, OAM within forty-five (45) days after the

completion of the testing. An extension may be granted by the IDEM, OAM, if the source

submits to IDEM, OAM, a reasonable written explanation within five (5) days prior to the

end of the initial forty-five (45) day period.

The documentation submitted by the Permittee does not require certification by the “authorized

individual” as defined by 326 IAC 2-1.1-1.

Compliance Monitoring Requirements 

C.9 Monitoring Methods [326 IAC 3]

Any monitoring or testing required by Section D of this permit shall be performed according to

the provisions of 326 IAC 3, 40 CFR 60, Appendix A, or other approved methods as specified in

this permit.

C.10 Actions Related to Noncompliance Demonstrated by a Stack Test

(a) When the results of a stack test performed in conformance with Section C -

Performance Testing, of this permit exceed the level specified in any condition of this

permit, the Permittee shall take appropriate corrective actions. The Permittee shall

submit a description of these corrective actions to IDEM, OAM, within thirty (30) days of

receipt of the test results. The Permittee shall take appropriate action to minimize

emissions from the affected emissions unit while the corrective actions are being

implemented. IDEM, OAM shall notify the Permittee within thirty (30) days, if the

corrective actions taken are deficient. The Permittee shall submit a description of

additional corrective actions taken to IDEM, OAM within thirty (30) days of receipt of the

notice of deficiency. IDEM, OAM reserves the authority to use enforcement activities to

resolve noncompliant stack tests.

(b) A retest to demonstrate compliance shall be performed within one hundred twenty (120)

days of receipt of the original test results. Should the Permittee demonstrate to IDEM,

OAM that retesting in one-hundred and twenty (120) days is not practicable, IDEM, OAM

may extend the retesting deadline. Failure of the second test to demonstrate

compliance with the appropriate permit conditions may be grounds for immediate

revocation of the permit to operate the affected emissions unit.

The documents submitted pursuant to this condition do not require the certification by the

“authorized individual” as defined by 326 IAC 2-1.1-1.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 11 of 26

Record Keeping and Reporting Requirements

C.11 Malfunctions Report [326 IAC 1-6-2] 

 Pursuant to 326 IAC 1-6-2 (Records; Notice of Malfunction):

(a) A record of all malfunctions, including startups or shutdowns of any facility or emission

control equipment, which result in violations of applicable air pollution control regulations

or applicable emission limitations shall be kept and retained for a period of three (3)

years and shall be made available to the Indiana Department of Environmental

Management (IDEM), Office of Air Management (OAM) or appointed representative 

upon request. 

(b) When a malfunction of any facility or emission control equipment occurs which lasts

more than one (1) hour, said condition shall be reported to OAM, using the Malfunction

Report Forms (2 pages). Notification shall be made by telephone or facsimile, as soon

as practicable, but in no event later than four (4) daytime business hours after the

beginning of said occurrence. 

(c) Failure to report a malfunction of any emission control equipment shall constitute a

violation of 326 IAC 1-6, and any other applicable rules. Information of the scope and

expected duration of the malfunction shall be provided, including the items specified in

326 IAC 1-6-2(a)(1) through (6).

(d) Malfunction is defined as any sudden, unavoidable failure of any air pollution control

equipment, process, or combustion or process equipment to operate in a normal and

usual manner. [326 IAC 1-2-39]

C.12 Monitoring Data Availability [326 IAC 2-6.1-2] [IC 13-14-1-13]

(a) With the exception of performance tests conducted in accordance with Section CPerformance Testing, all observations, sampling, maintenance procedures, and record

keeping, required as a condition of this permit shall be performed at all times the

equipment is operating at normal representative conditions. 

(b) As an alternative to the observations, sampling, maintenance procedures, and record

keeping of subsection (a) above, when the equipment listed in Section D of this permit is

not operating, the Permittee shall either record the fact that the equipment is shut down

or perform the observations, sampling, maintenance procedures, and record keeping

that would otherwise be required by this permit.

(c) If the equipment is operating but abnormal conditions prevail, additional observations

and sampling should be taken with a record made of the nature of the abnormality. 

(d) If for reasons beyond its control, the operator fails to make required observations,

sampling, maintenance procedures, or record keeping, reasons for this must be

recorded. 

(e) At its discretion, IDEM may excuse such failure providing adequate justification is

documented and such failures do not exceed five percent (5%) of the operating time in

any quarter. 
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 12 of 26

(f) Temporary, unscheduled unavailability of staff qualified to perform the required

observations, sampling, maintenance procedures, or record keeping shall be considered

a valid reason for failure to perform the requirements stated in (a) above.

C.13 General Record Keeping Requirements [326 IAC 2-6.1-2]

(a) Records of all required monitoring data and support information shall be retained for a

period of at least five (5) years from the date of monitoring sample, measurement,

report, or application. These records shall be kept at the source location for a minimum

of three (3) years and available upon the request of an IDEM, OAM, representative. The

records may be stored elsewhere for the remaining two (2) years as long as they are

available upon request. If the Commissioner makes a written request for records to the

Permittee, the Permittee shall furnish the records to the Commissioner within a

reasonable time.

(b) Records of required monitoring information shall include, where applicable:

(1) The date, place, and time of sampling or measurements;

(2) The dates analyses were performed;

(3) The company or entity performing the analyses;

(4) The analytic techniques or methods used;

(5) The results of such analyses; and 

(6) The operating conditions existing at the time of sampling or measurement.

(c) Support information shall include, where applicable:

(1) Copies of all reports required by this permit;

(2) All original strip chart recordings for continuous monitoring instrumentation; 

(3) All calibration and maintenance records;

(4) Records of preventive maintenance shall be sufficient to demonstrate that 

failure to implement the Preventive Maintenance Plan did not cause or

contribute to a violation of any limitation on emissions or potential to emit. To be

relied upon subsequent to any such violation, these records may include, but are

not limited to: work orders, parts inventories, and operator’s standard operating

procedures. Records of response steps taken shall indicate whether the

response steps were performed in accordance with the Compliance Response

Plan required by Section C - Compliance Monitoring Plan - Failure to take

Response Steps, of this permit, and whether a deviation from a permit condition

was reported. All records shall briefly describe what maintenance and response

steps were taken and indicate who performed the tasks.

(d) All record keeping requirements not already legally required shall be implemented when

operation begins.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 13 of 26

C.14 General Reporting Requirements [326 IAC 2-1.1-11] [326 IAC 2-6.1-2] [IC 13-14-1-13] 

(a) To affirm that the source has met all the compliance monitoring requirements stated in

this permit the source shall submit a Quarterly Compliance Monitoring Report. Any

deviation from the requirements and the date(s) of each deviation must be reported. 

The Compliance Monitoring Report shall include the certification by the “authorized

individual” as defined by 326 IAC 2-1.1-1(1).

 (b) The report required in (a) of this condition and reports required by conditions in Section

D of this permit shall be submitted to:

Indiana Department of Environmental Management

Compliance Data Section, Office of Air Management

100 North Senate Avenue, P. O. Box 6015

Indianapolis, Indiana 46206-6015

(c) Unless otherwise specified in this permit, any notice, report, or other submission

required by this permit shall be considered timely if the date postmarked on the envelope

or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or

before the date it is due. If the document is submitted by any other means, it shall be

considered timely if received by IDEM, OAM, on or before the date it is due.

(d) Unless otherwise specified in this permit, any quarterly report shall be submitted within

thirty (30) days of the end of the reporting period. The report does not require the

certification by the “authorized individual” as defined by 326 IAC 2-1.1-1(1).

(e) All instances of deviations must be clearly identified in such reports. A reportable

deviation is an exceedance of a permit limitation or a failure to comply with a

requirement of the permit or a rule. It does not include:

(1) An excursion from compliance monitoring parameters as identified in Section D

of this permit unless tied to an applicable rule or limit; or

(2) A malfunction as described in 326 IAC 1-6-2; or

(3) Failure to implement elements of the Preventive Maintenance Plan unless lack

of maintenance has caused or contributed to a deviation.

(4) Failure to make or record information required by the compliance monitoring

provisions of Section D unless such failure exceeds 5% of the required data in

any calendar quarter.

A Permittee’s failure to take the appropriate response step when an excursion of a

compliance monitoring parameter has occurred or failure to monitor or record the

required compliance monitoring is a deviation.

(f) Any corrective actions or response steps taken as a result of each deviation must be

clearly identified in such reports.

(g) The first report shall cover the period commencing on the date of issuance of this permit

and ending on the last day of the reporting period.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 14 of 26

C.15 Annual Notification [326 IAC 2-6.1-5(a)(5)] 

(a) Annual notification shall be submitted to the Office of Air Management stating whether or

not the source is in operation and in compliance with the terms and conditions contained

in this permit. 

(b) Noncompliance with any condition must be specifically identified. If there are any permit

conditions or requirements for which the source is not in compliance at any time during

the year, the Permittee must provide a narrative description of how the source did or will

achieve compliance and the date compliance was, or will be, achieved. The notification

must be signed by an authorized individual.

(c) The annual notice shall cover the time period from January 1 to December 31 of the

previous year, and shall be submitted in the format attached no later than March 1 of

each year to:

Compliance Data Section, Office of Air Management

 Indiana Department of Environmental Management

100 North Senate Avenue, P.O. Box 6015

Indianapolis, IN 46206-6015

(d) The notification shall be considered timely if the date postmarked on the envelope or

certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or

before the date it is due. If the document is submitted by any other means, it shall be

considered timely if received by IDEM, OAM, on or before the date it is due.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 15 of 26

SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS

Emissions Unit Description

(The information describing the process contained in this emissions unit description box is descriptive

information and does not constitute enforceable conditions.) 

(a) One (1) hard chromium electroplating operation, identified as HC-1, using a composite meshpad system for control, having a rectifier with a maximum potential capacity of 5,000 amperes

and exhausting to one (1) stack identified as S1; and

(b) One (1) hard chromium electroplating operation, identified as HC-2, using a composite meshpad system for control, having a rectifier with a maximum potential capacity of 5,000 amperes

and exhausting to one (1) stack identified as S1.

Emission Limitations and Standards [326 IAC 2-6.1-5(1)]

D.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR Part 63, Subpart A]

The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated by

reference as 326 IAC 20-1-1, apply to the facility described in this section except when

otherwise specified in 40 CFR Part 63, Subpart N. The permittee shall comply with the

requirements of this condition on and after the compliance date for the tanks.

D.1.2 Chromium Electroplating NESHAP [326 IAC 20-8-1] [40 CFR Part 63, Subpart N]

The provisions of 40 CFR 63, Subpart N - National Emission Standards for Chromium Emissions

From Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks, which are

incorporated by reference as 326 IAC 20-8-1, apply to tanks (HC-1 and HC-2). A copy of this

rule is attached. The permittee shall comply with the requirements of this condition on and after

the compliance date for the tanks.

D.1.3 Chromium Emissions Limitation [40 CFR 63.342(c)] [40 CFR 63.343(a)(1)&(2)]

(a) The emission limitations in this condition apply only during tank operation, and also

apply during periods of startup and shutdown as these are routine occurrences for tanks

subject to 326 IAC 20-8-1. The emission limitations do not apply during periods of

malfunction. 

(b) The hard chromium electroplating tanks, identified as (HC-2) above, is considered a

small, new hard chromium electroplating operation. During tank operation, the

Permittee shall control chromium emissions discharged to the atmosphere from the

tanks by not allowing the concentration of total chromium in the exhaust gas stream

discharged to the atmosphere to exceed 0.015 mg/dscm [6.6x10-6 gr/dscf]. 

(c) The hard chromium electroplating tanks, identified as (HC-1) above, is considered a

small, existing hard chromium electroplating operation. During tank operation, the

Permittee shall control chromium emissions discharged to the atmosphere from the hard

chromium electroplating tanks by not allowing the concentration of total chromium in the

exhaust gas stream discharged to the atmosphere to exceed 0.03 mg/dscm [1.3x10-5

gr/dscf]. 
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 16 of 26

D.1.4 Work Practice Standards [40 CFR 63.342(f)]

The following work practice standards apply to tanks (HC-1 and HC-2):

(a) At all times, including periods of startup, shutdown, malfunction and excess emissions,

the Permittee shall operate and maintain tanks (HC-1 and HC-2), including the add-on

control device (composite mesh-pad system) and monitoring equipment, in a manner

consistent with good air pollution control practices, consistent with the Operation and

Maintenance Plan (OMP) required by Condition D.1.6.

(b) Malfunctions and excess emissions shall be corrected as soon as practicable after their

occurrence in accordance with the OMP required by Condition D.1.6.

(c) These operation and maintenance requirements are enforceable independent of

emissions limitations or other requirements in this section.

(d) Determination of whether acceptable operation and maintenance procedures are being

used will be based on information available to IDEM, OAM, which may include, but is not

limited to, monitoring results; review of the OMP, procedures, and records; and

inspection of the source.

(e) Based on the results of a determination made under paragraph (d) of this condition,

IDEM, OAM may require that the Permittee make changes to the OMP required by

Condition D.1.6. Revisions may be required if IDEM, OAM finds that the plan:

(A) Does not address a malfunction or period of excess emissions that has

occurred;

(B) Fails to provide for the operation of tanks (HC-1 and HC-2), the add-on control

device (composite mesh-pad system) and process monitoring equipment during

a malfunction or period of excess emissions in a manner consistent with good

air pollution control practices; or

(C) Does not provide adequate procedures for correcting malfunctioning process

equipment, monitoring equipment or other causes of excess emissions as

quickly as practicable.

For tank (HC-2), the permittee shall comply with the requirements of this condition on and after

the start-up date of each tank. 

The work practice standards that address operation and maintenance must be followed during

malfunctions and periods of excess emissions. 

D.1.5 Preventive Maintenance Plan [326 IAC 1-6-3]

A Preventive Maintenance Plan (PMP), in accordance with Section B-Preventive Maintenance

Plan, of this permit, is required for the tanks (HC-1 and HC-2) and the add-on control device

(composite mesh-pad system).

D.1.6 Operation and Maintenance Plan [40 CFR 63.342(f)(3)]

(a) The Permittee shall prepare an Operation and Maintenance Plan (OMP) to be

implemented no later than the startup date of tanks (HC-1 and HC-2). The OMP shall

specify the operation and maintenance criteria for the tanks, the add-on control device

(composite mesh-pad system) and monitoring equipment and shall include the following

elements:
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 17 of 26

(1) For the composite mesh-pad system (CMP):

(A) Quarterly visual inspections of the device to ensure there is proper

drainage, no chromic acid buildup on the pads, and no evidence of

chemical attack on the structural integrity of the device.

(B) Quarterly visual inspection of the back portion of the mesh pad closest

to the fan to ensure there is no breakthrough of chromic acid mist;

(C) Quarterly visual inspection of the duct work from the tanks to the control

device to ensure there are no leaks;

(D) Perform washdown of the composite mesh pads in accordance with

manufacturer’s recommendations.

(2) A standardized checklist to document the operation and maintenance criteria for

tanks (HC-1 and HC-2), the air pollution control device, the add-on air pollution

control device and monitoring equipment;

(3) Procedures to be followed to ensure that equipment or process malfunctions

due to poor maintenance or other preventable conditions or periods of excess

emissions as indicated by monitoring data do not occur;

(4) A systematic procedure for identifying malfunctions and periods of excess

emissions of tanks (HC-1 and HC-2), the air pollution control device, the add-on

air pollution control device and monitoring equipment; and for implementing

corrective actions to address such malfunctions and periods of excess

emissions;

(b) The Permittee may use applicable standard operating procedures (SOP) manuals,

Occupational Safety and Health Administration (OSHA) plans, or other existing plans

such as the PMP required in Condition D.1.5, as the OMP, provided the alternative plans

meet the above listed criteria in Condition D.1.6(a).

(c) If the OMP fails to address or inadequately addresses an event that meets the

characteristics of a malfunction or period of excess emissions at the time the plan is

initially developed, the Permittee shall revise the OMP within forty five (45) days after

such an event occurs. The revised plan shall include procedures for operating and

maintaining tanks (HC-1 and HC-2), the air pollution control device, the add-on air

pollution control device and the monitoring equipment, during similar malfunction or

period of excess emissions events, and a program for corrective action for such events.

(d) If actions taken by the Permittee during periods of malfunction or period of excess

emissions are inconsistent with the procedures specified in the OMP, the Permittee shall

record the actions taken for that event and shall report by phone such actions within two

(2) working days after commencing actions inconsistent with the plan. This report shall

be followed by a letter within seven (7) working days after the end of the event, unless

the Permittee makes alternative reporting arrangements, in advance, with IDEM, OAM.

(e) The Permittee shall keep the written OMP on record after it is developed to be made

available, upon request, by IDEM, OAM for the life of tanks (HC-1 and HC-2) or until the

tank is no longer subject to the provisions of 40 CFR 63.340. In addition, if the OMP is

revised, the Permittee shall keep previous versions of the OMPs on record to be made

available for inspection, upon request by IDEM, OAM for a period of five (5) years after

each revision to the plan.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 18 of 26

Compliance Determination Requirements [326 IAC 2-1.1-11]

D.1.7 Performance Testing [326 IAC 2-1.1-11] [40 CFR 63.343(b)(2)] [40 CFR 63.7] [40 CFR 63.344]

(a) A performance test demonstrating initial compliance for tank (CH-1) was performed on

March 23, 1997. 

During the initial performance test, it was determined that the average pressure drop

across the composite mesh pad system was 1.96 ±1 inches of water and the average

outlet chromium concentration is 0.01048 mg/dscm. 

(b) The Permittee is required to conduct an initial performance test within 180 days after

startup of tank (HC-2) using the procedures and methods in 40 CFR 63.344 and 40 CFR

63.7 and in accordance with Section C - Performance Testing.

(c) The Permittee is not required to further test tank (HC-1 and HC-2) by this permit. 

However, the IDEM may require testing when necessary to determine if the tank is in

compliance. If testing is required by the IDEM, compliance with the limits specified in

Condition D.1.3 shall be determined by a performance test conducted in accordance

with 40 CFR 63.344 and Section C - Performance Testing.

(d) Any change, modification, or reconstruction of the tanks (HC-1 and HC-2), the add-on

control device (composite mesh-pad system) or monitoring equipment may require

additional performance testing conducted in accordance with 40 CFR 63.344 and

Section C - Performance Testing.

Compliance Monitoring Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2) ]

D.1.8 Monitoring to Demonstrate Continuous Compliance [326 IAC 2-6.1-5(a)(2)] [40 CFR 63.343(c)]

(c) Pursuant to 40 CFR 63.343(c)(1)(ii), when using a composite mesh-pad system to

comply with the limits specified in Condition D.1.3, the Permittee shall monitor and

record the pressure drop across the composite mesh-pad system during tank operation

once each day that the hard chromium electroplating tank is operating. To be in

compliance with the standards, the composite mesh-pad system shall be operated

within ±1 inch of water column of the pressure drop value established during the initial

performance test, or within the range of compliant values for pressure drop established

during multiple performance tests.

(d) Tank operation or operating time is defined as that time when a part is in the tank and

the rectifier is turned on. If the amount of time that no part is in the tank is fifteen

minutes or longer, that time is not considered operating time. Likewise, if the amount of

time between placing parts in the tank (i.e., when no part is in the tank) is less that

fifteen minutes, that time between plating the two parts is considered operating time.

D.1.9 Record Keeping Requirements [40 CFR 63.346]

The Permittee shall maintain records to document compliance with Conditions D.1.3, D.1.4 and

D.1.6 using the forms provided with this permit. These records shall be maintained in

accordance with Section C “General Record Keeping Requirements” of this permit, and include

a minimum of the following:

(a) Inspection records for the add-on control device (composite mesh pad system)

and monitoring equipment to document that the inspection and maintenance

required by Conditions D.1.7 and D.1.8 have taken place. The record can take

the form of a checklist and should identify the following:
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 19 of 26

(1) The device inspected;

(2) The date of inspection;

(3) A brief description of the working condition of the device during the

inspection, including any deficiencies found; and

(4) Any actions taken to correct deficiencies found during the inspection,

including the date(s) such actions were taken.

(b) Records of all maintenance performed on tanks (HC-1 and HC-2), the add-on

control device (composite mesh pad system) and monitoring equipment.

(c) Records of the occurrence, duration, and cause (if known) of each malfunction

of tanks (HC-1 and HC-2), the add-on control device (composite mesh pad

system) and monitoring equipment.

(d) Records of the occurrence, duration, and cause (if known) of each period of

excess emissions of tanks (HC-1 and HC-2), the add-on control device

(composite mesh-pad system) and monitoring equipment as indicated by

monitoring data collected in accordance with this condition.

(e) Records of actions taken during periods of malfunction when such actions are

inconsistent with the OMP.

(f) Other records, which may take the form of checklists, necessary to demonstrate

consistency with the provisions of the OMP.

(g) Test reports documenting results of all performance tests.

(h) All measurements as may be necessary to determine the conditions of

performance tests, including measurements necessary to determine

compliance.

(i) Records of monitoring data required by 40 CFR 63.343(c) that are used to

demonstrate compliance with the standard including the date and time the data

are collected.

(j) The total process operating time, as defined in Condition D.1.9(b), of each tank,

during the reporting period.

(k) Records of the actual cumulative rectifier capacity of each hard chromium

electroplating tank expended during each month of the reporting period, and the

total capacity expended to date for a reporting period.

(l) All documentation supporting the notifications and reports required by 

40 CFR 63.9 and 63.10 (Subpart A, General Provisions) and by Condition D.1.8

11.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 20 of 26

D.1.10 Reporting Requirements [326 IAC 3-6-4(b)] [40 CFR 63.344(a), 63.345 and 63.347]

The notifications and reports required in this section shall be submitted to IDEM, OAM using the

address specified in Section C - General Reporting Requirements.

(a) Notifications:

(1) Initial Notifications

The Permittee shall notify IDEM, OAM in writing that the source is subject to 40

CFR Part 63, Subpart N. The notification shall be submitted no later than one

hundred eighty (180) days after the compliance date and shall contain the

information listed in 40 CFR 63.347(c)(1). 

(2) A Notification of Compliance Status (NCS) is required each time that the facility

becomes subject to the requirements of 40 CFR Part 63 Subpart N. 

(A) The NCS shall be submitted to IDEM, OAM, and shall list, for each tank,

the information identified in 40 CFR 63.347(e)(2).

(B) The NCS for tank(s) (HC-1 and HC-2) shall be submitted to IDEM, OAM

no later than forty-five (45) days following completion of the compliance

demonstration pursuant to Section C - Performance Testing.

(3) Notification of Construction or Reconstruction

Pursuant to 40 CFR 63.345(b)(1), the Permittee may not construct a new tank

subject to 40 CFR 63, Subpart N (including non-affected tanks defined in 40

CFR 63.344(e)) without submitting a Notification of Construction or

Reconstruction (NCR) to IDEM, OAM. In addition, the Permittee may not

change, modify, or reconstruct tanks (HC-1 and HC-2) without submitting a

Notification of Construction or Reconstruction (NCR) to IDEM, OAM. 

(A) The NCR shall contain the information identified in 40 CFR 63.345(b)

(2) and (3).

(B) A change, modification, or reconstruction of this facility includes any

change in the air pollution control techniques, the addition of add-on

control devices, or the construction of duct work for the purpose of

controlling both existing tanks and non-affected facilities by a common

control technique or device.

(C) A complete application to construct new chromium electroplating or

chromium anodizing tanks serves as this notification. Likewise, the

complete application to modify or reconstruct tanks (HC-1 and HC-2)

serves as this notification.

(D) Pursuant to 326 IAC 2-1.1-2(a), permission must be received from

IDEM, OAM before construction, modification, or reconstruction may

commence.

(b) Performance Test Results

The Permittee shall document results from the initial performance test and any future

performance tests in a complete test report that contains the information required in 40

CFR 344(a).
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 21 of 26

The Permittee shall submit reports of performance test results as part of the Notification

of Compliance Status, described in 40 CFR 63.347(e), no later than forty-five (45) days

following the completion of the performance test.

(c) Ongoing Compliance Status Report

The Permittee shall prepare summary reports to document the ongoing compliance

status of tanks (HC-1 and HC-2) using the Ongoing Compliance Status Report form

provided with this permit. This report shall contain the information specified in 40 CFR

63.347(g)(3).

Because tanks (HC-1 and HC-2) are located at site that is an area source of hazardous

air pollutants (HAPs), the Ongoing Compliance Status Report shall be retained on site

and made available to IDEM, OAM upon request. 

(1) The Ongoing Compliance Status Report shall be completed according to the

following schedule except as provided in paragraphs (c)(2).

(A) The first report shall cover the period from the start-up date of the

emissions units to December 31 of the year in which the emissions units

begin operation.

(B) Following the first year of reporting, the report shall be completed on a

calendar year basis with the reporting period covering from January 1 to

December 31.

(2) If either of the following conditions are met, semiannual reports shall be

prepared and submitted to IDEM, OAM:

(A) The total duration of excess emissions (as indicated by the monitoring

data collected by the Permittee in accordance with 40 CFR 63.343(c)) is

one percent (1%) or greater of the total operating time as defined in

Condition D.1.8(b) for the reporting period; or

(B) The total duration of malfunctions of the add-on air pollution control

device and monitoring equipment is five percent (5%) or greater of the

total operating time as defined in Condition D.1.8(b).

Once the Permittee reports an exceedance as defined above, Ongoing

Compliance Status Reports shall be submitted semiannually until a request to

reduce reporting frequency in accordance with 40 CFR 63.347(g)(2) is

approved.

(3) IDEM, OAM may determine on a case-by-case basis that the summary report

shall be completed more frequently and submitted, or that the annual report

shall be submitted instead of being retained on site, if these measures are

necessary to accurately assess the compliance status of the source.
Page 22 of 26

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR MANAGEMENT

COMPLIANCE DATA SECTION

MINOR SOURCE OPERATING PERMIT

ANNUAL NOTIFICATION

This form should be used to comply with the notification requirements under 

326 IAC 2-6.1-5(a)(5). 

Company Name: Cope Brothers Machine Shop

Address: 5301 E SR 231, Leroy, IN 46355

City: Leroy

Phone #: 219-663-5661

MSOP #: 089-11760-00452

I hereby certify that Cope Brothers Machine Shop is 9 still in operation. 

9 no longer in operation.

I hereby certify that Cope Brothers Machine Shop is 

9 in compliance with the requirements of MSOP 089-11760-00452.

9 not in compliance with the requirements of MSOP 089-11760-00452.

Authorized Individual (typed):

Title:

Signature:

Date:

If there are any conditions or requirements for which the source is not in compliance, provide a narrative

description of how the source did or will achieve compliance and the date compliance was, or will be

achieved.

Noncompliance:
Page 23 of 26

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR MANAGEMENT

COMPLIANCE DATA SECTION

PART 70 OPERATING PERMIT

CHROMIUM ELECTROPLATING NESHAP

ONGOING COMPLIANCE STATUS REPORT

Source Name: Cope Brothers Machine Shop

Source Address: 5301 E SR 231, Leroy, IN 46355

Mailing Address: 5301 E SR 231, Leroy, IN 46355

MSOP No.: 089-11760-00452

Tank ID #: HC-1 and HC-2_____________________________

Type of process: Hard chromium electroplating operation

Monitoring Parameter: Pressure drop across the composite mesh pad system

Parameter Value: ±1 inch of water column of the pressure drop value established during the initial

performance test, or within the range of compliant values for pressure drop established

during multiple performance tests

Limits: The concentration of total chromium in the exhaust gas stream discharged to the atmosphere from Stack

S-1 of HC-1 and HC-2 shall not exceed 0.015 milligrams of total chromium per dry standard cubic meter

(mg/dscm).

This form is to be used to report compliance for the Chromium Electroplating NESHAP only.

The frequency for completing this report may be altered by the IDEM, OAM, Compliance Branch. 

Companies classified as a major source: submit this report no later than 30 days after the end of the reporting period.

Companies classified as an area source: complete this report no later than 30 days after the end of the reporting period,

and retain on site unless otherwise notified.

This form consists of 2 pages Page 1 of 2

BEGINNING AND ENDING DATES OF THE REPORTING PERIOD:

TOTAL OPERATING TIME OF THE TANK DURING THE REPORTING PERIOD:

MAJOR AND AREA SOURCES: CHECK ONE

9 NO DEVIATIONS OF THE MONITORING PARAMETER ASSOCIATED WITH THIS TANK FROM THE COMPLIANT VALUE OR

RANGE OF VALUES OCCURRED DURING THIS REPORTING PERIOD.

9 THE MONITORING PARAMETER DEVIATED FROM THE COMPLIANT VALUE OR RANGE OF VALUES DURING THIS

REPORTING PERIOD (THUS INDICATING THE EMISSION LIMITATION MAY HAVE BEEN EXCEEDED, WHICH COULD

RESULT IN MORE FREQUENT REPORTING).

AREA (I.E., NON-MAJOR) SOURCES OF HAP ONLY:

IF DEVIATIONS OCCURRED, LIST THE AMOUNT OF TANK OPERATING TIME EACH MONTH THAT MONITORING RECORDS

SHOW THE MONITORING PARAMETER DEVIATED FROM THE COMPLIANT VALUE OR RANGE OF VALUES.

JAN APR JUL OCT

FEB MAY AUG NOV

MAR JUN SEP DEC

HARD CHROME TANKS / MAXIMUM RECTIFIER CAPACITY LIMITED IN ACCORDANCE WITH 40 CFR 63.342(c)(2) ONLY:

LIST THE ACTUAL AMPERE-HOURS CONSUMED (BASED ON AN AMP-HR METER) BY THE INDIVIDUAL TANK.

JAN APR JUL OCT

FEB MAY AUG NOV

MAR JUN SEP DEC
Page 24 of 26

CHROMIUM ELECTROPLATING NESHAP

ONGOING COMPLIANCE STATUS REPORT

ATTACH A SEPARATE PAGE IF NEEDED Page 2 of 2

IF THE OPERATION AND MAINTENANCE PLAN REQUIRED BY 40 CFR 63.342 (f)(3) WAS NOT FOLLOWED, PROVIDE AN

EXPLANATION OF THE REASONS FOR NOT FOLLOWING THE PLAN AND DESCRIBE THE ACTIONS TAKEN FOR THAT EVENT:

DESCRIBE ANY CHANGES IN TANKS, RECTIFIERS, CONTROL DEVICES, MONITORING, ETC. SINCE THE LAST STATUS REPORT:

ADDITIONAL COMMENTS:

ALL SOURCES: CHECK ONE

9 I CERTIFY THAT THE WORK PRACTICE STANDARDS IN 40 CFR 63.342(f) WERE FOLLOWED IN ACCORDANCE WITH

THE OPERATION AND MAINTENANCE PLAN ON FILE; AND, THAT THE INFORMATION CONTAINED IN THIS REPORT IS

ACCURATE AND TRUE TO THE BEST OF MY KNOWLEDGE.

9 THE WORK PRACTICE STANDARDS IN 40 CFR 63.342(f) WERE NOT FOLLOWED IN ACCORDANCE WITH THE

OPERATION AND MAINTENANCE PLAN ON FILE, AS EXPLAINED ABOVE AND/OR ON ATTACHED.

Submitted by: 

Title/Position: 

Signature:

Date:

Phone: 

Attach a signed certification to complete this report.
Page 25 of 26

Rev 3/99

MALFUNCTION REPORT

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR MANAGEMENT

FAX NUMBER - 317 233-5967

This form should only be used to report malfunctions applicable to Rule 326 IAC 1-6

and to qualify for the exemption under 326 IAC 1-6-4.

THIS FACILITY MEETS THE APPLICABILITY REQUIREMENTS BECAUSE IT HAS POTENTIAL TO EMIT 25 TONS/YEAR 

PARTICULATE MATTER ?_____, 25 TONS/YEAR SULFUR DIOXIDE ?_____, 25 TONS/YEAR NITROGEN OXIDES?_____, 

25 TONS/YEAR VOC ?_____, 25 TONS/YEAR HYDROGEN SULFIDE ?_____, 25 TONS/YEAR TOTAL REDUCED SULFUR

?_____, 25 TONS/YEAR REDUCED SULFUR COMPOUNDS ?_____, 25 TONS/YEAR FLUORIDES ?_____, 100TONS/YEAR

CARBON MONOXIDE ?_____, 10 TONS/YEAR ANY SINGLE HAZARDOUS AIR POLLUTANT ?_____, 25 TONS/YEAR ANY

COMBINATION HAZARDOUS AIR POLLUTANT ?_____, 1 TON/YEAR LEAD OR LEAD COMPOUNDS MEASURED AS

ELEMENTAL LEAD ?_____, OR IS A SOURCE LISTED UNDER 326 IAC 2-5.1-3(2) ?_____. EMISSIONS FROM

MALFUNCTIONING CONTROL EQUIPMENT OR PROCESS EQUIPMENT CAUSED EMISSIONS IN EXCESS OF

APPLICABLE LIMITATION ________.

THIS MALFUNCTION RESULTED IN A VIOLATION OF: 326 IAC _______ OR, PERMIT CONDITION # _______ AND/OR

PERMIT LIMIT OF _______________

THIS INCIDENT MEETS THE DEFINITION OF ‘MALFUNCTION’ AS LISTED ON REVERSE SIDE ? Y N

THIS MALFUNCTION IS OR WILL BE LONGER THAN THE ONE (1) HOUR REPORTING REQUIREMENT ? Y N

COMPANY:__Cope Brothers Machine Shop_______________________PHONE NO. ( 317)758-5260__________________

LOCATION: (CITY AND COUNTY)__Leroy, IN, Lake County___________________________________________________

PERMIT NO. 089-11760-00452 AFS PLANT ID: _057-00452_____ AFS POINT ID: _____________ INSP:_Rick Massoels__________

CONTROL/PROCESS DEVICE WHICH MALFUNCTIONED AND REASON:_____________________________________________

__________________________________________________________________________________________________________

DATE/TIME MALFUNCTION STARTED: _____/_____/ 20____ _____________________________________________ AM / PM

ESTIMATED HOURS OF OPERATION WITH MALFUNCTION CONDITION: ___________________________________________

DATE/TIME CONTROL EQUIPMENT BACK-IN SERVICE______/______/ 20____ _______________ AM/PM

TYPE OF POLLUTANTS EMITTED: TSP, PM-10, SO2, VOC, OTHER:___________________________________________

ESTIMATED AMOUNT OF POLLUTANT EMITTED DURING MALFUNCTION: _________________________________________

_________________________________________________________________________________________________________

MEASURES TAKEN TO MINIMIZE EMISSIONS:_________________________________________________________________

_________________________________________________________________________________________________________

REASONS WHY FACILITY CANNOT BE SHUTDOWN DURING REPAIRS:

CONTINUED OPERATION REQUIRED TO PROVIDE ESSENTIAL* SERVICES:_______________________________________

CONTINUED OPERATION NECESSARY TO PREVENT INJURY TO PERSONS:_______________________________________

CONTINUED OPERATION NECESSARY TO PREVENT SEVERE DAMAGE TO EQUIPMENT:____________________________

INTERIM CONTROL MEASURES: (IF APPLICABLE)______________________________________________________________

_________________________________________________________________________________________________________

_________________________________________________________________________________________________________

MALFUNCTION REPORTED BY:___________________________________TITLE:_____________________________

 (SIGNATURE IF FAXED)

MALFUNCTION RECORDED BY:_______________________DATE:__________________TIME:__________________

*SEE PAGE 2

PAGE 1 OF 2
Page 26 of 26

Rev 3/99

Please note - This form should only be used to report malfunctions

applicable to Rule 326 IAC 1-6 and to qualify for

the exemption under 326 IAC 1-6-4.

326 IAC 1-6-1 Applicability of rule

Sec. 1. This rule applies to the owner or operator of any facility required to obtain a

permit under 326 IAC 2-5.1 or 326 IAC 2-6.1.

326 IAC 1-2-39 “Malfunction” definition

Sec. 39. Any sudden, unavoidable failure of any air pollution control equipment, process, or

combustion or process equipment to operate in a normal and usual manner. 

*Essential services are interpreted to mean those operations, such as, the providing of electricity by

power plants. Continued operation solely for the economic benefit of the owner or operator shall not be

sufficient reason why a facility cannot be shutdown during a control equipment shutdown.

If this item is checked on the front, please explain rationale:

________________________________________________________________________

________________________________________________________________________

PAGE 2 OF 2
Page 1 of 5

Indiana Department of Environmental Management

Office of Air Management

Technical Support Document (TSD) for a Construction and Minor Source

Operating Permit 

Source Background and Description

Source Name: Cope Brothers Machine Shop

Source Location: 5301 E SR 231, Leroy, IN 46355

County: Lake

SIC Code: 3471

MSOP No.: 089-11760-00452

Permit Reviewer: Phillip Ritz/EVP

The Office of Air Management (OAM) has reviewed an application from Cope Brothers Machine

Shop relating to the construction and operation of a hard chromium electroplating operation.

New Emission Units and Pollution Control Equipment

The source consists of the following permitted emission units and pollution control devices:

(a) One (1) hard chromium electroplating operation, identified as HC-2, using a composite

mesh-pad system for control, having a rectifier with a maximum potential capacity of

5,000 amperes and exhausting to one (1) stack identified as S1.

Unpermitted Emission Units and Pollution Control Equipment

The source consists of the following unpermitted emission units and pollution control devices: 

(a) One (1) hard chromium electroplating operation, identified as HC-1, using a composite

mesh-pad system for control, having a rectifier with a maximum potential capacity of

5,000 amperes and exhausting to one (1) stack identified as S1.

(b) One (1) hot water boiler, with a maximum rated heat input of 0.150 mmBtu of natural gas.

(c) Two (2) space heaters, each with a maximum rated heat input of 0.175 mmBtu of natural

gas.

Permitted Emission Units and Pollution Control Equipment

There are no permitted facilities operating at this source during this review process.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 2 of 5

Stack Summary

Stack ID Operation Height 

(feet)

Diameter 

(feet)

Flow Rate

 (acfm)

Temperature

 (0F)

 S-1 Tank HC-1 and HC225 1 22,800 Ambient

Enforcement Issue

There are no enforcement actions pending.

Recommendation

The staff recommends to the Commissioner that the operation be approved. This

recommendation is based on the following facts and conditions:

Unless otherwise stated, information used in this review was derived from the application and

additional information submitted by the applicant.

A complete application for the purposes of this review was received on December 27, 1999.

Emission Calculations

(a) Chromium emissions (Single HAP) from the biggest source in Indiana is less than (10)

tons per year and Cope Brothers Machine Shop is a much smaller source in

comparison. So no calculations were necessary for the hard chromium electroplating

operation because the emissions from this source will be less than ten (10) tons per

year. 

(b) See Appendix A of this document for detailed natural gas combustion emissions

calculations (Appendix A, page 1 of 1.)

Potential To Emit 

Pursuant to 326 IAC 2-1.1-1(16), Potential to Emit is defined as “the maximum capacity of a

stationary source or emissions unit to emit any air pollutant under its physical and operational

design. Any physical or operational limitation on the capacity of a source to emit an air pollutant,

including air pollution control equipment and restrictions on hours of operation or type or amount

of material combusted, stored, or processed shall be treated as part of its design if the limitation

is enforceable by the U. S. EPA, the department, or the appropriate local air pollution control

agency.” 

Pollutant Potential To Emit (tons/year)

PM 0.00

PM-10 0.02

SO2 0.00

VOC 0.01

CO 0.20

NOx 0.24

HAP’s Potential To Emit (tons/year)

Nickel Compounds Less Than 10

Chromium Compounds Less Than 10

 TOTAL Less Than 25
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 3 of 5

(a) The potential to emit (as defined in 326 IAC 2-7-1(29)) of any single HAP is less than ten

(10) tons per year and the potential to emit (as defined in 326 IAC 2-7-1(29)) of a

combination HAPs is less than twenty-five (25) tons per year. Therefore, the source is

not subject to the provisions of 326 IAC 2-7.

(b) This new source is subject to 326 IAC 20-8 but not subject to 326 IAC 2-5.5-1 (b)(2)

(registration) because the source consists of only hard chromium (not decorative

chromium) electroplating tanks and the source emits less than major source levels (see

statement (a) above). Therefore, the source is subject to the provisions of 326 IAC 2-

6.1-3(a).

Actual Emissions

No previous emission data has been received from the source.

County Attainment Status

The source is located in Lake County.

Pollutant Status

PM-10 attainment

SO2 attainment

NO2 attainment

Ozone severe nonattainment

CO attainment

Lead attainment

(a) Volatile organic compounds (VOC) and oxides of nitrogen are precursors for the

formation of ozone. Therefore, VOC and NOx emissions are considered when

evaluating the rule applicability relating to the ozone standards. Lake County has been

designated as nonattainment for ozone. Therefore, VOC and NOx emissions were

reviewed pursuant to the requirements for Emission Offset, 326 IAC 2-3.

Source Status

Existing Source PSD, Part 70 or FESOP Definition (emissions after controls, based on 8,760

hours of operation per year at rated capacity and/ or as otherwise limited): 

Pollutant Emissions

 (ton/yr)

PM 0.00

PM10 0.02

SO2 0.00

VOC 0.01

CO 0.20

NOx 0.24

Single HAP <10.0 each HAP

Combination HAPs <25.0

(a) This new source is not a major stationary source because ozone is not emitted at a rate

of 25 tons per year or greater. Therefore, pursuant to 326 IAC 2-3, the Emission Offset

requirements do not apply.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 4 of 5

Part 70 Permit Determination

326 IAC 2-7 (Part 70 Permit Program)

This existing source is not subject to the Part 70 Permit requirements because the potential to

emit (PTE) of:

(a) each criteria pollutant is less than 100 tons per year,

(b) a single hazardous air pollutant (HAP) is less than 10 tons per year, and

(c) any combination of HAPs is less than 25 tons/year.

Although this source is subject to the National Emission Standards for Hazardous Air Pollutants

(NESHAPs), 326 IAC 14, (40 CFR 63, Subpart N), no Title V permit is required pursuant to 40

CFR 63.340(e).

This is the first air approval issued to this source.

Federal Rule Applicability

(a) There are no New Source Performance Standards (NSPS)(326 IAC 12 and 40 CFR Part

60) applicable to this source.

(b) The chromium electroplating operations are subject to the National Emission Standards

for Hazardous Air Pollutants (NESHAPs), 326 IAC 14, (40 CFR 63, Subpart N, and 326

IAC 20-1-1). Pursuant to 40 CFR 63, Subpart N, and 326 IAC 20-1-1, the chromium

electroplating operations are subject to the following conditions:

(1) The surface tension of the chromium electroplating bath contained with the tank

shall not exceed forty-five (45) dynes per centimeter at any time during the

operation of the tank if a chemical fume suppressant containing a wetting agent

is used to demonstrate compliance.

(2) Each time that surface tension monitoring exceeds forty-five (45) dynes per

centimeter, the frequency of monitoring must revert back to every four (4) hours

of tank operation. After forty (40) hours of monitoring tank operation every four

(4) hours with no exceedances, surface tension measurement may be

conducted once every eight (8) hours of tank operation. Once there have been

no exceedances during forty (40) hours of tank operation, surface tension

measurement may be conducted once every forty (40) hours of tank operation

on an ongoing basis, until an exceedance occurs.

(3) An alternative emission limit of 0.01 milligram per day standard cubic meter

(mg/dscm) will be applicable if the chromium electroplating bath does not meet

the limit above.

(4) A summary report shall be prepared to document the ongoing compliance status

of the chromium electroplating operation. This report shall be completed

annually, retained on site, and made available to IDEM upon request. If there

are significant exceedance of chromium air emission limits (as defined in 40

CFR Part 63.347(h)(2)), then semiannual reports shall be submitted to:

Indiana Department of Environmental Management

Air Compliance Branch, Office of Air Management

Chromium Electroplating

100 North Senate Avenue, P.O. Box 6015

Indianapolis, Indiana 46206 
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 5 of 5

(5) The chromium electroplating operations shall be subject to the record keeping

and reporting requirement as indicated in the chromium electroplating NESHAP.

State Rule Applicability - Entire Source

326 IAC 2-6 (Emission Reporting)

This source is located in Lake County and the potential to emit VOC and NOx is less than ten

(10) tons per year. Therefore, 326 IAC 2-6 does not apply.

326 IAC 5-1 (Opacity Limitations)

Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3

(Temporary Exemptions), opacity shall meet the following, unless otherwise stated in this permit:

(a) Opacity shall not exceed an average of twenty percent (20%) in any one (1) six (6)

minute averaging period as determined in 326 IAC 5-1-4.

(b) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen

(15) minutes (sixty (60) readings) as measured according to 40 CFR 60, Appendix A,

Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a

continuous opacity monitor in a six (6) hour period.

Air Toxic Emissions

Indiana presently requests applicants to provide information on emissions of the 188 hazardous

air pollutants (HAPs) set out in the Clean Air Act Amendments of 1990. These pollutants are

either carcinogenic or otherwise considered toxic and are commonly used by industries. They

are listed as air toxics on the Office of Air Management (OAM) Construction Permit Application

Form Y. 

(a) This source will emit levels of air toxics less than those which constitute a major source

according to Section 112 of the 1990 Clean Air Act Amendments.

Conclusion

The operation of this hard chromium electroplating operation shall be subject to the conditions of

the attached proposed Construction and Minor Source Operating Permit 089-11760-00452.
Page 1 of 10

Indiana Department of Environmental Management

Office of Air Management

Addendum to the

Technical Support Document for a Construction Permit

and Minor Source Operating Permit 

Source Name: Cope Brothers Machine Shop

Source Location: 5301 E SR 231, Leroy, IN 46355

County: Lake

SIC Code: 3471

MSOP No.: 089-11760-00452

Permit Reviewer: Phillip Ritz/EVP

On March 17, 2000, the Office of Air Management (OAM) had a notice published in The Post

Tribune in Gary and The Times in Munster, Indiana, stating that Cope Brothers Machine Shop, had

applied for a New Source Construction Permit and Minor Source Operating Permit to construct a new

emission unit and operate a hard chromium electroplating operation with control. The notice also stated

that OAM proposed to issue a permit for this installation and provided information on how the public

could review the proposed Construction Permit and Minor Source Operating Permit and other

documentation. Finally, the notice informed interested parties that there was a period of thirty (30) days

to provide comments on whether or not this permit should be issued as proposed.

Upon further review, the OAM has decided to make the following revisions to the permit to

incorporate updated language for new hard chromium electroplating operations (bolded language has

been added, the language with a line through it has been deleted). The Table Of Contents has been

modified to reflect these changes.

(a) Conditions D.1.1 through D.1.4 in the permit section entitled “Emission Limitations and

Standards” have been revised as shown below to: (1) clarify the units or control devices subject

to conditions; (2) be more consistent with the language of the Chromium Electroplating NESHAP

and (3) add the requirement to address excess emissions as well as malfunctions if they occur.

By this permit, the Permittee is approved to use a composite mesh-pad system as the emission

reduction technique to comply with the Chromium Electroplating NESHAP. However, IDEM,

OAM encourages the Permittee to also consider the use of fume suppressants to comply as this

technique can achieve a greater degree of emission reductions. Use of fume suppressants can

be approved in a permit modification as an alternative means of compliance in addition to or

instead of the composite mesh-pad system.

D.1.1 General Provisions Relating to HAPs [326 IAC 20-1-1][40 CFR Part 63, Subpart A]

The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated by

reference as 326 IAC 20-1-1, apply to the facility described in this section except when

otherwise specified in 40 CFR Part 63, Subpart N. The permittee shall comply with the

requirements of this condition on and after the compliance date for the tanks.

\
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 2 of 10

D.1.2 Chromium Electroplating NESHAP [326 IAC 20-8-1] [40 CFR Part 63, Subpart N]

This facility is subject to 40 CFR Part 63, Subpart N, The provisions of 40 CFR 63, Subpart N -

National Emission Standards for Chromium Emissions From Hard and Decorative

Chromium Electroplating and Chromium Anodizing Tanks, which is are incorporated by

reference as 326 IAC 20-8-1, apply to tanks (HC-1 and HC-2). A copy of this rule is attached.

The permittee shall comply with the requirements of this condition on and after the

compliance date for the tanks.

D.1.3 Chromium Emissions Limitation [40 CFR 63.342(c)] [40 CFR 63.343(a)(1)&(2)]

(a) The emission limitations in this condition apply only during tank operation, and

also apply during periods of startup and shutdown as these are routine

occurrences for tanks subject to 326 IAC 20-8-1. The emission limitations do not

apply during periods of malfunction. 

(b) The hard chromium electroplating tanks, identified as (HC-2) above, is considered

a small, new hard chromium electroplating operation. During tank operation, the

Permittee shall control chromium emissions discharged to the atmosphere from

the tanks by not allowing the concentration of total chromium in the exhaust gas

stream discharged to the atmosphere to exceed 0.015 mg/dscm [6.6x10-6 gr/dscf]. 

(a) The Permittee shall not allow the concentration of total chromium in the exhaust gas

stream discharged to the atmosphere from Stack S1 of HC-1 and HC-2 to exceed 0.03

milligrams of total chromium per dry standard cubic meter (mg/dscm) of ventilation air

(1.3 x 10-5 grains per dry standard cubic foot (gr/dscf)).

(c) The hard chromium electroplating tanks, identified as (HC-1) above, is considered

a small, existing hard chromium electroplating operation. During tank operation,

the Permittee shall control chromium emissions discharged to the atmosphere

from the hard chromium electroplating tanks by not allowing the concentration of

total chromium in the exhaust gas stream discharged to the atmosphere to exceed

0.03 mg/dscm [1.3x10-5 gr/dscf]. 

(b) The work practice standards for HC-1 and HC-2 are also applicable:

D.1.4 Work Practice Standards [40 CFR 63.342(f)]

The following work practice standards apply to tanks (HC-1 and HC-2):

(1)(a) At all times, including periods of startup, shutdown, malfunction and excess emissions,

the Permittee shall operate and maintain tanks (HC-1 and HC-2), including the add-on

control device (composite mesh-pad system) and monitoring equipment, in a manner

consistent with good air pollution control practices, consistent with the Operation

and Maintenance Plan (OMP) required by Condition D.1.6.

(2)(b) Malfunctions and excess emissions shall be corrected as soon as practicable after

their occurrence in accordance with the OMP required by Condition D.1.46.

(c) These operation and maintenance requirements are enforceable independent of

emissions limitations or other requirements in this section.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 3 of 10

(3)(d) Determination of whether acceptable operation and maintenance procedures are being

used will be based on information available to IDEM, OAM, which may include, but is not

limited to, monitoring results; review of the OMP, procedures, and records; and

inspection of the source.

(4)(e) Based on the results of a determination made under (3),paragraph (d) of this

condition, IDEM, OAM may require that the Permittee make changes to the OMP

required by Condition D.1.6. Revisions may be required if IDEM, OAM finds that the

plan:

(1)(A) Does not address a malfunction or period of excess emissions that has

occurred;

(2)(B) Fails to provide for the operation of tanks (HC-1 and HC-2), the add-on control

techniques, or the device (composite mesh-pad system) and process

monitoring equipment during a malfunction or period of excess emissions in a

manner consistent with good air pollution control practices; or

(3)(C) Does not provide adequate procedures for correcting malfunctioning process

equipment, monitoring equipment or other causes of excess emissions as

quickly as practicable.

For tank (HC-2), the permittee shall comply with the requirements of this condition on and

after the start-up date of each tank. 

The work practice standards that address operation and maintenance must be followed

during malfunctions and periods of excess emissions. 

D.1.3 5 Preventive Maintenance Plan [326 IAC 1-6-3]

A Preventive Maintenance Plan (PMP), in accordance with Section B-Preventive Maintenance

Plan, of this permit, is required for the tanks (HC-1 and HC-2) and the add-on control device

(composite mesh-pad system).

D.1.46 Operation and Maintenance Plan [40 CFR 63.342(f)(3)]

(a) An Operation and Maintenance Plan (OMP), in accordance with 40 CFR 63.342(f)(3)

The Permittee shall prepare an Operation and Maintenance Plan (OMP) to be

implemented no later than the startup date of tanks (HC-1 and HC-2). The OMP

shall specify the operation and maintenance criteria for HC-1 and HC-2 the tanks, the

add-on control device (composite mesh-pad system) and monitoring equipment and

shall include the following elements:

(1) For the composite mesh-pad system (CMP):

(A) Quarterly visual inspections of the composite mesh pad system device

to ensure there is proper drainage, no chromic acid buildup on the pads,

and no evidence of chemical attack on the structural integrity of the

device.

(2)(B) Quarterly visual inspection of the back portion of the mesh pad closest

to the fan to ensure there is no breakthrough of chromic acid mist;

(3)(C) Quarterly visual inspection of the duct work from the tanks to the control

device to ensure there are no leaks;
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 4 of 10

(4)(D) Perform washdown of the composite mesh pads in accordance with

manufacturer’s recommendations.

(52) A standardized checklist to document the operation and maintenance criteria for

tanks (HC-1 and HC-2), the composite mesh pad system, air pollution control

device, the add-on air pollution control device and monitoring equipment;

(63) Procedures to be followed to ensure that equipment or process malfunctions

due to poor maintenance or other preventable conditions or periods of excess

emissions as indicated by monitoring data do not occur;

(74) A systematic procedure for identifying malfunctions and periods of excess

emissions of tanks (HC-1 and HC-2), the composite mesh pad system, air

pollution control device, the add-on air pollution control device and

monitoring equipment; and for implementing corrective actions to address such

malfunctions and periods of excess emissions;

(b) The Permittee may use applicable standard operating procedures (SOP) manuals,

Ooccupational Ssafety and Hhealth Aadministration (OSHA) plans, or other existing

plans such as the PMP required in Condition D.1.3 5, as the OMP, provided the

alternative plans meet the criteria listed above listed criteria in Condition D.1.4 6(a).

(c) If the OMP fails to address or inadequately addresses an event that meets the

characteristics of a malfunction or period of excess emissions at the time the plan is

initially developed, the Permittee shall revise the OMP within forty five (45) days after

such an event occurs. The revised plan shall include procedures for operating and

maintaining tanks (HC-1 and HC-2), the composite mesh pad system, the air pollution

control device, the add-on air pollution control device and the monitoring

equipment, during similar malfunction or period of excess emissions events, and a

program for corrective action for such events.

(d) If actions taken by the Permittee during periods of malfunction or period of excess

emissions are inconsistent with the procedures specified in the OMP, the Permittee

shall record the actions taken for that event and shall report by phone such actions

within two (2) working days after commencing actions inconsistent with the plan. This

report shall be followed by a letter within seven (7) working days after the end of the

event, unless the Permittee makes alternative reporting arrangements, in advance, with

IDEM, OAM.

(e) The Permittee shall keep the written OMP on record after it is developed to be made

available, upon request, by IDEM, OAM for the life of tanks (HC-1 and HC-2) or until the

tank HC-1 and HC-2 is no longer subject to the provisions of 40 CFR 63.340. In

addition, if the OMP is revised, the Permittee shall keep previous versions of the OMPs

on record to be made available for inspection, upon request by IDEM, OAM for a period

of five (5) years after each revision to the plan.

(b) Conditions D.1.5 and D.1.6 in the permit section entitled “Compliance Determination

Requirements” have been revised as shown below to: (1) be more consistent with the language

of the Chromium Electroplating NESHAP; (2) relocate monitoring conditions more properly in a

section entitled “Compliance Monitoring;” (3) add state rule citations; (4) list the results of exiting

tank (CH-1) performance tests; and (5) relocate the definition of “tank operation and operating

time” from the Recordkeeping and Reporting section of the permit to the Compliance Monitoring

section since the definition applies to monitoring as well.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 5 of 10

D.1.57 Performance Testing [40 CFR 63.343, 63.344, and 63.7] [326 IAC 2-1.1-11] [40 CFR

63.343(b)(2)] [40 CFR 63.7] [40 CFR 63.344]

(a) Within 36 months after issuance of this permit, the Permittee shall perform outlet

chromium concentration testing utilizing the procedures and methods listed in 40 CFR

63.344 and 63.7 and in accordance with the provisions of Condition C.8 - Performance

Testing of this permit. In addition to these requirements, IDEM may require compliance

testing when necessary to determine if the emissions unit is in compliance.

(b) During the initial performance test, the Permittee shall determine the outlet chromium

concentration of the composite mesh-pad system using the test methods and

procedures in 40 CFR 63.344(c) and shall establish as a site-specific operating

parameter the pressure drop across the system, setting the value that corresponds to

compliance with the emission limitation in Condition D.1.2(a) using the procedures in 40

CFR 63.344(d)(5). The Permittee may conduct multiple performance tests to establish a

range of compliant pressure drop values, or may set as the compliant value the average

pressure drop measured over the three (3) test runs of one performance test, and

accept ±1 inch of water column from this value as the compliant range.

(a) A performance test demonstrating initial compliance for tank (CH-1) was

performed on March 23, 1997. 

During the initial performance test, it was determined that the average pressure

drop across the composite mesh pad system was 1.96 ±1 inches of water and the

average outlet chromium concentration is 0.01048 mg/dscm. 

(b) The Permittee is required to conduct an initial performance test within 180 days

after startup of tank (HC-2) using the procedures and methods in 40 CFR 63.344

and 40 CFR 63.7 and in accordance with Section C - Performance Testing.

(c) The Permittee is not required to further test tank (HC-1 and HC-2) by this permit. 

However, the IDEM may require testing when necessary to determine if the tank is

in compliance. If testing is required by the IDEM, compliance with the limits

specified in Condition D.1.3 shall be determined by a performance test conducted

in accordance with 40 CFR 63.344 and Section C - Performance Testing.

(d) Any change, modification, or reconstruction of the tanks (HC-1 and HC-2), the addon control device (composite mesh-pad system) or monitoring equipment may

require additional performance testing conducted in accordance with 40 CFR

63.344 and Section C - Performance Testing.

Compliance Monitoring Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2) ]

There are no compliance monitoring requirements applicable to this facility.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 6 of 10

D.1.8 Monitoring to Demonstrate Continuous Compliance [326 IAC 2-6.1-5(a)(2)] [40 CFR

63.343(c)]

(c) Pursuant to 40 CFR 63.343(c)(1)(ii), when using a composite mesh-pad system to

comply with the limits specified in Condition D.1.3, the Permittee shall monitor and

record the pressure drop across the composite mesh-pad system during tank

operation once each day that the hard chromium electroplating tank is operating. 

To be in compliance with the standards, the composite mesh-pad system shall be

operated within ±1 inch of water column of the pressure drop value established

during the initial performance test, or within the range of compliant values for

pressure drop established during multiple performance tests.

(d) Tank operation or operating time is defined as that time when a part is in the tank

and the rectifier is turned on. If the amount of time that no part is in the tank is

fifteen minutes or longer, that time is not considered operating time. Likewise, if

the amount of time between placing parts in the tank (i.e., when no part is in the

tank) is less that fifteen minutes, that time between plating the two parts is

considered operating time.

(c) Conditions D.1.7 and D.1.8 in the permit section entitled “Record Keeping and Reporting

Requirements” have been revised as shown below to: (1) be more consistent with the language

of the Chromium Electroplating NESHAP; (2) add the requirement to address excess emissions

as well as malfunctions if they occur; (3) require more frequent reporting if either total duration of

excess emissions or malfunctions exceed thresholds established in the NESHAP instead of both

having to occur; and (4) include all notifications and reporting required for sources by the

NESHAP.

It is emphasized that where the permit states that approval is required for changes to

recordkeeping or reporting conditions (such as changes in reporting frequency), the approval

shall come from IDEM, OAM. All requests for changes and approvals must be made consistent

with the permitting rules in 326 IAC Article 2. That is, the proper applications must be submitted

if necessary, and all approvals shall be subject to the time lines for issuance stated in the rules.

D.1.79 Record Keeping Requirements [40 CFR 63.346]

(a)The Permittee shall maintain records to document compliance with Conditions D.1.13, D.1.4

and D.1.46 using the forms provided with this permit. These records shall be maintained in

accordance with the Section C condition entitled “General Record Keeping Requirements” of

this permit, be kept for a period of five (5) years, and include a minimum of the following:

(1)(a) Inspection records for the add-on control device (composite mesh pad system)

and monitoring equipment to document that the inspection and maintenance

required by Conditions D.1.3 7 and D.1.4 8 have taken place. The record can

take the form of a checklist and should identify the following:

(A1) The device inspected;

(B2) The date of inspection;

(C3) A brief description of the working condition of the device during the

inspection, including any deficiencies found; and

(D4) Any actions taken to correct deficiencies found during the inspection,

including the date(s) such actions were taken.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 7 of 10

(2b) Records of all maintenance performed on tanks (HC-1 and HC-2), the add-on

control device (composite mesh pad system) and monitoring equipment.

(3c) Records of the occurrence, duration, and cause (if known) of each malfunction

of tanks (HC-1 and HC-2), the add-on control device (composite mesh pad

system) and monitoring equipment.

(d) Records of the occurrence, duration, and cause (if known) of each period

of excess emissions of tanks (HC-1 and HC-2), the add-on control device

(composite mesh-pad system) and monitoring equipment as indicated by

monitoring data collected in accordance with this condition.

(4e) Records of actions taken during periods of malfunction when such actions are

inconsistent with the OMP.

(5f) Other records, which may take the form of checklists, necessary to demonstrate

consistency with the provisions of the OMP.

(6g) Test reports documenting results of all performance tests.

(h) and all All measurements as may be necessary to determine the conditions of

performance tests, including measurements necessary to determine

compliance.

(7i) Records of monitoring data required by 40 CFR 63.343(c) that are used to

demonstrate compliance with the standard including the date and time the data

are collected.

(8) The specific identification of each period of excess emissions, as indicated by

monitoring data, that occurs during periods of malfunction of HC-1 and HC-2,

the composite mesh pad system, and monitoring equipment.

(9) The specific identification of each period of excess emissions, as indicated by

monitoring data, that occurs during periods other than malfunction of HC-1 and

HC-2, the composite mesh pad system, and monitoring equipment.

(10j) The total process operating time, as defined in Condition D.1.9(b), of HC-1

and HC-2 each tank, during the reporting period.

(k) Records of the actual cumulative rectifier capacity of each hard chromium

electroplating tank expended during each month of the reporting period,

and the total capacity expended to date for a reporting period.

(11l) All documentation supporting the notifications and reports required by 

40 CFR 63.9 and 63.10 (Subpart A, General Provisions) and by Condition D.1.8

11.

(b) Operating time for chrome electroplating is defined as that time when the rectifier is

turned on and a part is in the tank. When there is no part in a tank for fifteen (15) or

more minutes, that time will not be considered operating time; likewise, if the time

between placing a part in the tank is less than fifteen (15) minutes, that time will be

considered part of the operating time.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 8 of 10

D.1.810Reporting Requirements [40 CFR 63.345 & 63.347] [326 IAC 3-6-4(b)] [40 CFR 63.344(a),

63.345 and 63.347]

(a) In accordance with 40 CFR 63.345, a notification must be submitted to IDEM, OAM prior

to any change, modification, or reconstruction of HC-1 and HC-2 (including addition of

duct work to the composite mesh pad system) or construction of a new facility or source

(affected or nonaffected, as defined in 40 CFR 63.344(e)). Notification shall be

submitted as soon as practicable, but no sooner than thirty (30) days before the date

construction or reconstruction commences.

The notifications and reports required in this section shall be submitted to IDEM, OAM

using the address specified in Section C - General Reporting Requirements.

(a) Notifications:

(1) Initial Notifications

The Permittee shall notify IDEM, OAM in writing that the source is subject

to 40 CFR Part 63, Subpart N. The notification shall be submitted no later

than one hundred eighty (180) days after the compliance date and shall

contain the information listed in 40 CFR 63.347(c)(1). 

(b) In accordance with 40 CFR 63.347(c)(2), a notification of the date when construction or

reconstruction was commenced shall be submitted to IDEM, OAM no later than thirty

(30) calendar days after such date. In addition, a notification of the actual date of startup

of the new or reconstructed facility or source shall be submitted to IDEM, OAM within

thirty (30) calendar days after such date. Additional notifications required under 40 CFR

63.345 and 63.347 shall be specified as they become due.

(2) A Notification of Compliance Status (NCS) is required each time that the

facility becomes subject to the requirements of 40 CFR Part 63 Subpart N. 

(A) The NCS shall be submitted to IDEM, OAM, and shall list, for each

tank, the information identified in 40 CFR 63.347(e)(2).

(B) The NCS for tank(s) (HC-1 and HC-2) shall be submitted to IDEM,

OAM no later than forty-five (45) days following completion of the

compliance demonstration pursuant to Section C - Performance

Testing.

(3) Notification of Construction or Reconstruction

Pursuant to 40 CFR 63.345(b)(1), the Permittee may not construct a new

tank subject to 40 CFR 63, Subpart N (including non-affected tanks defined

in 40 CFR 63.344(e)) without submitting a Notification of Construction or

Reconstruction (NCR) to IDEM, OAM. In addition, the Permittee may not

change, modify, or reconstruct tanks (HC-1 and HC-2) without submitting a

Notification of Construction or Reconstruction (NCR) to IDEM, OAM. 

(A) The NCR shall contain the information identified in 40 CFR

63.345(b) (2) and (3).

(B) A change, modification, or reconstruction of this facility includes

any change in the air pollution control techniques, the addition of

add-on control devices, or the construction of duct work for the

purpose of controlling both existing tanks and non-affected

facilities by a common control technique or device.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 9 of 10

(C) A complete application to construct new chromium electroplating

or chromium anodizing tanks serves as this notification. Likewise,

the complete application to modify or reconstruct tanks (HC-1 and

HC-2) serves as this notification.

(D) Pursuant to 326 IAC 2-1.1-2(a), permission must be received from

IDEM, OAM before construction, modification, or reconstruction

may commence.

(c) The Permittee shall notify IDEM, OAM in writing of their intention to conduct a

performance test at least sixty (60) calendar days before the test is scheduled to begin.

Reports of performance test results shall be submitted no later than forty-five (45) days

following the completion of the performance test, and shall be submitted as part of a

notification of compliance status as described in 40 CFR 63.347(e), to the address listed

in the Section C condition entitled “Performance Testing” of this permit.

(b) Performance Test Results

The Permittee shall document results from the initial performance test and any

future performance tests in a complete test report that contains the information

required in 40 CFR 344(a).

The Permittee shall submit reports of performance test results as part of the

Notification of Compliance Status, described in 40 CFR 63.347(e), no later than

forty-five (45) days following the completion of the performance test.

(dc) Ongoing Compliance Status Report

The Permittee shall submit a prepare summary reports to document the ongoing

compliance status of tanks (HC-1 and HC-2) using the Ongoing Compliance Status

Report form provided with this permit. TheThis report shall contain the information

specified in 40 CFR 63.347(g)(3) that is applicable.

(1) This report shall be submitted semiannually on a calendar year basis, unless

otherwise directed by IDEM, OAM. The report shall be submitted within thirty

(30) days after the end of each reporting period, which ends June 30 and

December 31 respectively.

(2) If there are any exceedances of the chromium air emission limit contained in

Condition D.1.1, then quarterly reports shall be submitted until a request to

reduce reporting frequency, according to the procedures of 40 CFR

63.347(g)(2), is approved.

Because tanks (HC-1 and HC-2) are located at site that is an area source of

hazardous air pollutants (HAPs), the Ongoing Compliance Status Report shall be

retained on site and made available to IDEM, OAM upon request. 

(1) The Ongoing Compliance Status Report shall be completed according to

the following schedule except as provided in paragraphs (c)(2).

(A) The first report shall cover the period from the start-up date of the

emissions units to December 31 of the year in which the emissions

units begin operation.
Cope Brothers Machine Shop

Leroy, Indiana MSOP089-11760-00452

Permit Reviewer: PR/EVP

Page 10 of 10

(B) Following the first year of reporting, the report shall be completed

on a calendar year basis with the reporting period covering from

January 1 to December 31.

(2) If either of the following conditions are met, semiannual reports shall be

prepared and submitted to IDEM, OAM:

(A) The total duration of excess emissions (as indicated by the

monitoring data collected by the Permittee in accordance with

40 CFR 63.343(c)) is one percent (1%) or greater of the total

operating time as defined in Condition D.1.8(b) for the reporting

period; or

(B) The total duration of malfunctions of the add-on air pollution

control device and monitoring equipment is five percent (5%) or

greater of the total operating time as defined in Condition D.1.8(b).

Once the Permittee reports an exceedance as defined above, Ongoing

Compliance Status Reports shall be submitted semiannually until a

request to reduce reporting frequency in accordance with 40 CFR

63.347(g)(2) is approved.

(3) IDEM, OAM may determine on a case-by-case basis that the summary

report shall be completed more frequently and submitted, or that the

annual report shall be submitted instead of being retained on site, if these

measures are necessary to accurately assess the compliance status of the

source.
Appendix A: Emissions Calculations Page 1 of 1 TSD App A

Natural Gas Combustion Only

 MM BTU/HR <100

Company Name: Cpe Brothers Machine Shop

Address City IN Zip: 5301 E SR 231, Leroy, IN 46355

CP: 089-11760

Plt ID: 089-00452

Reviewer: Phillip Ritz/EVP

Date: January 11, 2000

Heat Input Capacity Potential Throughput

MMBtu/hr MMCF/yr

0.5 4.7

One (1) Hot water boiler, with a maximum rated heat input of .15 mmBtu per hour

Two (2) space heaters, each with a maximum rated heat input of .175 mmBtu per hour

Pollutant

PM* PM10* SO2 NOx VOC CO

Emission Factor in lb/MMCF 1.9 7.6 0.6 100.0 5.5 84.0

**see below

Potential Emission in tons/yr 0.00 0.02 0.00 0.24 0.01 0.20

*PM emission factor is filterable PM only. PM10 emission factor is filterable and condensable PM10 combined.

**Emission Factors for NOx: Uncontrolled = 100, Low NOx Burner = 50, Low NOx Burners/Flue gas recirculation = 32

Methodology

All emission factors are based on normal firing.

MMBtu = 1,000,000 Btu

MMCF = 1,000,000 Cubic Feet of Gas

Potential Throughput (MMCF) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMCF/1,000 MMBtu

Emission Factors are from AP 42, Chapter 1.4, Tables 1.4-1, 1.4-2, 1.4-3, SCC #1-02-006-02, 1-01-006-02, 1-03-006-02, and 1-03-006-03

(SUPPLEMENT D 3/98)

Emission (tons/yr) = Throughput (MMCF/yr) x Emission Factor (lb/MMCF)/2,000 lb/ton

factors to

emission

above

using the