• • • 

Siale of IIIil10is 

ENVIRONMENTAL PROTECTION AGENCY 

Mary A. Gade, Director 

217/782-2113 

P. O. Box 19506, Springfield, IL 6279,1-9506 

OPERATING PERMIT FOR HARD CHROME ELECTROPLATING OPERATION 

NESHAP SOURCE 

PE:RtHTTE£ 

Empire Hard Chrome , Inc . 

Attn : Steve Hallin 

1615 South Kastne r Avenue 

Chicago, Illinois 60623 

Applicat~on No .: 73032100 

Applicant ' s Designation ; 90-997 

Subject : Hard chrome Electroplating 

Dat e Issued : Harch 21 , 1996 

Location : 1615 South Kastner Avenue, 

1 . 0 . No.: 031600CUQ 

Da te Received : Janua ry 5, 1996 

Ex piration Date: March 21, 2001 

Chicago 

This permit is hereby gran ted to the above-designated Permittee to OPERATE 

emission source(s) and/o r air pollution control eqUipment consisting of 

t welve hard c h r ome electroplating tank(s) A-4 - A-a, A-123, 8-1, B-7, 8-2, 

8-5, 8-6, and 8-34 controlled by packed bed scrubbe rs, three gas fired air 

makeup units, and three sandblast units controlled by dust collector as 

desc ribed in the above-referenced application. Th i s permit is subject to 

standard conditions attached hereto and the followi ng special 

condition(s) : 

la . Air pollution control equipment associated with a hard chrome 

e lectropla ti ng t ank(s) shall be operated a t all times during the 

operation of the tank. 

b. Hard chrome electroplating tank(s) shall not e xceed the following 

limits, pursuant to 40 CFR 63.342(c) (1) : 

Hard ChromiUm Plating Tanks 

Existing Large Tank(s) 

Chromium Emissions 

mg/dscm 

0 . 015 

This limit is the Na tional Emissions standa rd for Hard Chromium 

Electroplating Tanks, 40 CFR Part 63 Subpart N and based on the 

maximum annual cumulative r ectifier capacity of the hard chrome 

electr oplating tanks being greater than 60 million amp - hrs/year. 

An electroplating tank(s) installed before December 16, 1993, is 

conside red as e xisting t a nk (s). Compliance with t he limit shall be 

determined from initial performance testing and ongoing compliance 

monitoring requirements, as =equired by Conditions of this permit. 

c . FailUre to operate in accordance with operating parameter value, 

determined during initial performance testi ng shall be considered a 

violation of the above limit, pursuant to 40 CFR 63 Subpart N. 

d . The Permittee shall be in compliance with 40 CFR Part 63 Subpart N -

National Emission Standard for hard chrome tank (s) on or before 

January 25, 1997 . 

/ 
Page 2 

2. The operation and maintenance practices required by 40 CFR 63.342(f) 

shall be implemented for control systems used on hard chrome plating 

tanks, including: 

The following operation and maintenance procedure for packed-bedscrubber(PBS) . 

a. A quarterly visual inspection of packed-bed scrubber to ensure 

there is proper drainage, no chromic acid buildup on the 

packed beds, and no evidence of chemical attack on the 

structural integrity of the devices. 

b. A quarterly visual inspection of back portion of the chevronblade mist eliminator to ensure that it is dry and there is no 

breakthrough of chromic acid mist. 

c. A quarterly visual inspection of duct work from the tank(s) to 

the control device to ensure there are no leaks. 

d. Add fresh make-up water to the top of the packed bed whenever 

makeup is added. 

3a. The Permittee shall develop and implement an operation and 

maintenance (0 & M) plan for hard chrome plating tanks which shall 

include at least the following, pursuant to 40 eFR 63.342(f) (3): 

i. Description of the control devices and monitoring equipment in 

use. 

ii. A checklist to document the operation and maintenance of the 

equipmen t. 

iii. Required operation and maintenance procedures, pursuant to 40 

CFR 63.342(f) (Condition 2). 

iv. Procedure to follow to ensure that equipment or process 

malfunctions due to poor maintenance or other preventable 

conditions do not occur. 

v. Procedure for identifying malfunctions and for implementing 

corrective actions. 

b. The Permittee may use any Standard Operating Procedure (SOP) 

manuals, Occupational Safety and Health Administration (OSHA) plans 

or other existing plans as part of operation and maintenance plan, 

as long as they meet all the criteria of Condition 3(a). 

4. Hard chrome electroplating tank(s) shall complete an initial 

performance test to demonstrate compliance pursuant to 40 CFR 

63.343(b). Emissions tests shall be conducted during conditions 

which are representative of maximum emissions, i.e. at maximum rated 

rectifier capacity of all tanks. The initial performance test shall 

be performed by July 24, 1997. 

o 
Page 3 

5. The following methods and procedures shall be used for performance 

testing: Refer to 40 CFR 63, Appendix A, for USEPA test methods. 

Location of sample Points 

Gas Flow and Velocity 

Chromium 

USEPA Method 1 

USEPA Method 2 

USEPA Method 306 & 306A 

6a. Prior to carrying out these tests, the Bureau of Air shall be 

notified in writing a minimum of sixty (60) calendar days prior to 

the scheduled date of these tests with the exact date, time and 

place of these tests, to enable the Agency to observe these tests, 

pursuant to 40 CFR 63.347(d). 

Illinois Environmental Protection Agency 

Bureau of Air 

Compliance Unit (#39) 

P.O. Box 19276 

Springfield, Illinois 62794-9276 

Illinois Environmental Protection Agency 

Division of Air Pollution Control - Regional Office 

Eisenhower Tower 

1701 First Avenue 

Maywood, Illinois 60153 

b. If the scheduled date for the test is changed for unforeseen reason, 

the Permittee shall inform the Agency within 5 calendar days of the 

originally scheduled test date and must specify the date of the 

rescheduled test. Observation of the performance test by the Agency 

is optional. 

7a. During testing, the site specific "operating parameter value", Le., 

range of pressure drop data across the scrubber will be established 

to demonstrate continuous compliance, pursuant to 40 CFR 63.343(c). 

Pressure drop range can be established from the highest and lowest 

value during the multiple performance testing or ± 1 inch of H20 

column about the average pressure drop measured during the three 

compliant test runs. 

b. During testing, the site specific "operating parameter value", Le., 

a range of velocity pressure drop data across the system inlet will 

be established to demonstrate continuous compliance, pursuant to 40 

CFR 63.343(c) (2). Velocity pressure drop range can be established 

from the highest and lowest value during the multiple performance 

testing or ± 10 percent about the average velocity pressure drop 

measured during the three compliant test runs. 

c. Two (2) copies of the Final Report(s) for emission tests and 

compliance status shall be submitted to the Agency within 90 days 

after the performance test. If testing is not required, report 

shall be submitted no later than 30 days of compliance date. 

i. General information, i.e., date of test, testing peraonnel and 

observers, if any. 

ii. A summary of results and compliance status. 
Page 4 

iii. Description of test method(s), including description of 

sampling points, sampling train, analysis equipment, and test 

schedule. 

iv. Detailed description of test conditions, including: 

A. Process information, i.e., models) of operation, process 

weight rate, e.g. raw material consumption, rectifier 

operating rate. 

B. ~ontrol equipment record of: 

1. Pressure drop range across the system to 

demonstrate continuous compliance. 

2. Range of velocity pressure at system inlet to 

demonstrate continuous compliance. 

c. A discussion of calibration procedure. 

v. Data and calculations, including copies of all raw data sheets 

and records of laboratory analyses, sample calculations, and 

data on equipment calibration. 

vi. An explanation of any discrepancies among individual tests or 

anomalous data. 

vii. Quality assurance procedure and result. 

viii. Any additional information required by the test method. 

d. Submittals of information shall be made as follows: 

i. Notices of Test - one copy to the Regional Office, and one 

copy to compliance unit. 

ii. Final Report - one copy to the Regional Office, and one copy 

to Compliance Unit. 

Illinois Environmental Protection Agency 

Bureau of Air 

compliance Unit (#39) 

P.O. Box 19276 

springfield, Illinois 62794-9276 

Illinois Environmental Protection Agency 

Division of Air Pollution control - Regional Office 

Eisenhower Tower 

1701 First Avenue 

Maywood, Illinois 60153 
Page 5 

8. The Permittee shall keep the records required by 40 eFR 63.346, to 

demonstrate compliance: including the following: 

a. Records of monitoring data required by 40 eFR 63.343(c). 

i. Pressure drop across the packed bed scrubber, determined 

daily. 

ii. Velocity pressure at system inlet, determined daily. 

b. Records of all maintenance performed on the chrome plating 

tanks, as related to emissions, the associated control system 

and monitoring equipment. 

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

each malfunction of the chrome plating process, associated 

control system and monitoring equipment. 

d. Records of actions taken during periods of malfunction when 

such actions are inconsistent with the operation and 

maintenance plan. 

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

demonstrate consistency with the operation and maintenance 

plan required by 40 eFR 63.342{f) (3). 

f. Copies of test reports documenting results of all performance 

tests and all measurements as may be necessary to determine 

the conditions of performance tests, including measurements 

necessary to determine compliance with the special compliance 

procedures of 40 eFR 63.344(e). 

g. Records of monitoring data required by 40 eFR 63.343(c) that 

are used to demonstrate compliance with the standard including 

the date and time the data are collected. 

h. The specific identification (i.e., the date and time of 

commencement and completion) of each period of excess 

emissions, as indicated by monitoring data. Records of excess 

emissions that occurs during malfunction of the process, 

control or monitoring equipment. 

i. The specific identification (i.e., the date and time of 

commencement and completion) of each period of excess 

emissions, as indicated by monitoring data. Records of excess 

emissions with that occurs during periods other than 

malfunction of the subject chrome plating tanks and associated 

control devices. 

j. Records for the total process operating time of the affected 

chrome plating tank(s) during the reporting period. 
Page 6 

k. Records demonstrating the maximum cumulative rectifier 

capacity if hard chrome plating is less than 60 million amphrs per year or of the actual cumulative rectifier capacity of 

hard chromium electroplating tank(s) at a facility expended 

during each month and the total capacity expended to 

semiannually. 

1. Copies of the notifications and reports required by 40 CFR 

Part 63.9, 63.10 and 63.347 (Condition 9 & 10) with supporting 

documentation. 

m. ~l records shall be retained for a period of five years, 

pursuant to 63.10(b) (1). 

9. The Permittee shall comply with the compliance reporting 

requirements of 40 CFR 63.347 including the following: 

A notification of compliance status, signed by the responsible 

official who shall certify its accuracy, attesting to whether the 

affected source has complied with Subpart N, pursuant to 40 CrR 

63.347(e). The notification shall list the following: 

a. The applicable emission limitation and the methods that were 

used to determine compliance with this limitation. 

b. The performance test report documenting the results of the 

performance test, which contains the elements required by 40 

CFR 63.344(a), including measurements and calculations to 

support the special compliance provisions of 40 CFR 63.344(e) 

if these are being followed. 

c. The type and quantity of hazardous air pollutants emitted by 

the source reported in mg/dscm or mg/hr if the source is using 

the special provisions of 40 CFR 63.344(e) to comply with the 

standards. 

lOa. The Permittee shall submit ongoing compliance status report 

documenting the ongoing compliance status to the Agency every six 

months. If the Permittee exceeds the emission limits as indicated 

during performance testing, ongoing compliance status shall be 

submitted on every quarter. 

b. The ongoing compliance report shall contain the following: 

i. The company name and address of the source performing hard 

chrome plates. 

ii. An identification of the operating parameter(s) that are 

monitored for compliance determination. 

iii. The relevant emission limitation for the source, and the 

operating parameter value, or range of values, that correspond 

to compliance with this emission limitation as specified in 

the notification of compliance status. 
Page 7 

iv. The beginning and ending dates of the reporting period. 

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

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

period. 

vii. The capacity cumulative rectifier actual expended during the 

reporting period, on a month-by-month basis, if the Permittee 

limits the maximum cumulative rectifier capacity less than 60 

million amp-hr/yr. 

viii. A summary of operating parameter values, including the total 

duration of excess emissions during the reporting period as 

indicated by those values, the total duration of excess 

emissions expressed as a percent of the total source operating 

time during that reporting period, and a breakdown of the 

total duration of excess emissions during the reporting period 

into those that are due to.process upsets, control equipment 

~alfunctions, other known causes, and unknown causes. 

ix. A certification by a responsible official that the work 

practice standards followed in accordance with the operation 

and maintenance plan for the source. 

x. If the operation and maintenance plan was not followed, an 

explanation of the reasons for not following the provisions, 

an assessment of whether any excess emission and/or parameter 

monitoring exceedances are believed to have occurred, and a 

copy of the report(s) documenting that the operation and 

maintenance plan was not followed. 

xi. A description of any changes in monitoring processes, or 

controls since the last reporting period. 

xii. The name, title, and signature of the responsible official who 

is certifying the accuracy of the report. 

xiii. The date of the report. 

c. The Permittee shall report the results for each monitoring device. 

However, when one monitoring device is used as a backup for the 

primary monitoring device, the Permittee shall only report the 

results from the monitoring device used to meet the monitoring 

requirements. If both devices are used to meet these requirements, 

then the owner or operator shall report the results from each 

monitoring device for the relevant compliance period. 

11. All notification and reports required by this permit shall be sent 

to the following address, unless otherwise indicated: 

Illinois EPA 

Bureau of Air 

Compliance Unit (#39) 

P.o. Box 19276 

Springfield, Illinois 62794-9276 
Page 8 

12a. Emissions and operation of air makeup units shall not exceed the 

following limits: 

Gas Consumption 

(rnmftJ /Mo) (rnrnftJ /Year) 

1. 90 22.76 

NOx Emissions 

(Lb/Mo) (Ton/Year) 

190 1.14 

These limits are based on maximum gas consumption and emissions are 

determined based on standard emission factor. 

b. Compliance with annual limits shall be determined from a running 

total of 12 months of data. 

c. Natural gas shall be the only fuel used in air makeup units. 

13. This permit is issued based on negligible emissions of PM from 

sandblasting units. For this purpose emissions shall not exceed 

nominal emissions rate of 0.1 lb/hr and 0.44 ton/yr. 

14. The Permittee shall also maintain gas consumption record (rnrnftJ/mo 

and rnrnftJ/yr) for at least three years. 

If you have any questions on this permit, please call Joydeb Majumder at 

217/782-2113. 

Donald E. sutton, P.E. 

Manager, Permit section 

Division of Air Pollution Control 

(\M I . /JA ____ 

DES:JM: jar f1P'~ 

cc: Region 1 

IEPA, Compliance Unit 

COpy 

Original Signed by 

Uonald E. Sutton, P. E. 
July I, 1985 

STATE OF ILLINOIS 

ENVIRONMENTAL PROTECTION AGENCY 

DIVISION OF AIR POLLUTION CONTROL 

2200 CHURCHILL ROAD 

SPRINGFIELD. ILLINOIS 62706 

STANDARD CONDITIONS 

FOR 

OPERATING PERMITS 

The Illinois Environmental Protection Act (Illinois Revised Statutes, Chapter 111-1/2, Section 1039) grants the 

Environmental Protection Agency authority to impose conditions on permits which it issues. 

The following conditions are applicable unless superseded by special permit condition(s). 

1. The issuance of this permit does not release the permittee from compliance with state and federal regulations 

which are part of the Illinois State Implementation Plan, as well as with other applicable statutes and regulations 

of the United States or the State of Illinois or with applicable local laws, ordinances and regulations. 

2. The Agency has issued this permit based upon the information submitted by the permittee in the permit 

application. Any misinformation, false statement or mispresentation in the application shall be grounds for 

revocation under 35 Ill. Adm. Code 201.207. 

3. a. The permittee shall not authorize, cause, direct or allow any modification, as defined in 35 Ill. Adm. Code 

201.102, of equipment, operations or practices which are reflected in the permit application as submitted 

unless a new application or request for revision of the existing permit is filed with the Agency and unless a 

new permit or revision of the existing permit(s) is issued for such modification. 

b. This permit only covers emission sources and control equipment while physically present at the indicated 

plant location(s). Unless the permit specifically provides for equipment relocation, this permit is void for an 

item of equipment on the day it is removed from the permitted location(s) or if all equipment is removed, 

notwithstanding the expiration date specified on the permit. 

4. The permittee shall allow any duly authorized agent of the Agency, upon the presentation of credentials, at 

reasonable times: 

a. to enter the permittee's property where actual or potential effluent, emission or noise sources are located or 

where any activity is to be conducted pursuant to this permit, 

b. to have access to and to copy any records required to be kept under the terms and conditions of this permit, 

c. to inspect, including during any hours of operation of equipment constructed or operated under this permit, 

such equipment and any equipment required to be kept, used, operated, calibrated and maintained under this 

permit, 

d. to obtain and remove samples of any discharge or emission of pollutants, and 

e. to enter and utilize any photographic, recording, testing, monitoring or other equipment for the purpose of 

preserving, testing, monitoring or recording any activity, discharge or emission authorized by this permit. 

5. The issuance of this permit: 

a. shall not be considered as in any manner affecting the title of the premises upon which the permitted 

facilities are located, 

b. does not release the permittee from any liability for damage to person or property caused by or resulting from 

the construction, maintenance. or operation of the facilities, 

IL 532-0224 09G-005 

APe 161 Rev. MaY-93 Print~ on Recycled Piper