September 7, 2001 

Mr. J. Michael Raymond

R&S Plating, Inc.

2302 Bloyd Ave.

Indianapolis, IN. 46218

Re: 097-14505-00325

First Administrative Amendment to

MSOP 097-11695-00325

Dear Mr. Raymond:

R&S Plating, Inc. was issued a permit on September 5, 2000 for a hard chromium electroplating

operation. A letter requesting an administrative amendment was received on June 18, 2001. Since this

amendment pertains to errors incorporated within the original permit, then pursuant to the provisions of

326 IAC 2-6.1-6(d)(2) the permit is hereby administratively amended as follows:

 

1. The following sections of the permit have been amended to exclude any mention of the

phrase “foam blanket-type fume suppressant” due to the erroneous insertion within the

original permit. In addition, mention of the phrase “mesh pad system or composite mesh

pad system” within these sections has also been removed due to its redundancy.

Furthermore, the following corrections have also been included: Section D.1.5 of the

original permit contained a typographical error and has been amended to include the

correct section to reference for the Preventive Maintenance Plan, Section D.1.7(a) and

Section D.1.8(b) were changed to reflect the correct average pressure drop as 2.5+/-1

inches of water due to an error incorporated in the original permit, Section D.1.8(b) has

been amended as a result of a telephone conversation with David Farlow of R&S Plating

in which Mr. Farlow requested the removal of the second part of the definition of

operating time, Section D.1.9(k) was incorrectly included in the original permit and has

been amended to exclude this particular sub-section. These sections are hereby

administratively amended as follows:

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 with a maximum cumulative rectifier capacity of

17,640,000 Ampere-hours consisting of: One (1) hard chromium electroplating tank, identified as

HC #1, equipped with a packed-bed scrubber/mesh-pad system and a foam blanket-type fume

suppressant as controls, equipped with a and composite mesh-pad as a common control, and

exhausting to one (1) stack, identified as Stack 2;

(b) One (1) hard chromium electroplating operation with a maximum cumulative rectifier capacity of

23,520,000 Ampere-hours consisting of: One (1) hard chromium electroplating tank, identified as

HC #2, equipped with a packed-bed scrubber/mesh-pad system and a foam blanket-type fume

suppressant as controls, equipped with a and composite mesh-pad as a common control, and

exhausting to one (1) stack, identified as Stack 2;
R&S Plating, INC. First Administrative Amendment Page 2 of 7

Indianapolis, IN. 097-14505-00325 OP No: 097-11695-00325

Permit Reviewer: SLD

SECTION D.1 FACILITY OPERATION CONDITIONS

Facility Description [326 IAC 2-7-5(15)]: Chromium Electroplating Operations

The information describing the process contained in this facility description box is descriptive

information and does not constitute enforceable conditions. 

(a) One (1) hard chromium electroplating operation with a maximum cumulative rectifier capacity

of 17,640,000 Ampere-hours consisting of: One (1) hard chromium electroplating tank,

identified as HC #1, equipped with a packed-bed scrubber/composite mesh-pad system and a

foam blanket-type fume suppressant as controls, equipped with a and composite mesh-pad as

a common control, and exhausting to one (1) stack, identified as Stack 2;

(b) One (1) hard chromium electroplating operation with a maximum cumulative rectifier capacity

of 23,520,000 Ampere-hours consisting of: One (1) hard chromium electroplating tank,

identified as HC #2, equipped with a packed-bed scrubber/composite mesh-pad system and a

foam blanket-type fume suppressant as controls, equipped with a and composite mesh-pad as

a common control, and exhausting to one (1) stack, identified as Stack 2;

D.1.4 Work Practice Standards [40 CFR 63.342(f)] [326 IAC 20-8-1]

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 packedbed scrubber/composite mesh-pad system and foam blanket-type fume suppressant,

and composite mesh-pad, and monitoring equipment, in a manner consistent with good

air

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

IDEM, OAQ and ERMD may require that the Permittee make changes to the OMP

required by Condition D.1.6. Revisions may be required if IDEM, OAQ and ERMD finds

that the plan:

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

occurred;

(2) Fails to provide for the operation of tanks HC #1 and HC #2, the packed-bed

scrubber/composite mesh-pad system, foam blanket-type fume suppressant,

and composite mesh-pad, and process monitoring equipment during a

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

pollution control practices; or,

 (3) Does not provide adequate procedures for correcting malfunction process

equipment, packed-bed scrubber/composite mesh-pad system, foam blankettype fume suppressant, and composite mesh-pad, monitoring equipment or

other causes of excess emissions as quickly as practicable.

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 packed-bed

scrubber/composite mesh-pad system, foam blanket-type fume suppressant, and composite

mesh-pad.

D.1.6 Operation and Maintenance Plan [40 CFR 63.342(f)(3)] [326 IAC 20-8-1]

(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 
R&S Plating, INC. First Administrative Amendment Page 3 of 7

Indianapolis, IN. 097-14505-00325 OP No: 097-11695-00325

Permit Reviewer: SLD

specify the operation and maintenance criteria for the tanks, the packed-bed

scrubber/composite mesh-pad system, foam blanket-type fume suppressant, and

composite mesh-pad and monitoring equipment and shall include the following

elements:

(1) For the packed-bed scrubber/composite mesh-pad system (PBS/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 tank to the control

device to ensure there are no leaks.

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

manufacturers recommendations.

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

tanks HC #1 and HC #2, the air pollution control technique, packed-bed

scrubber/composite mesh-pad system, foam blanket-type fume suppressant,

and composite mesh-pad, and the monitoring equipment.

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]

[326 IAC 20-8-1]

(a) A performance test demonstrating initial compliance for tanks HC #1 and HC #2 was

performed on May 19, 1997. During the initial performance test, it was determined that

the average overall pressure drop across the composite mesh pad system was 3.0

2.5+/-1 inches of water for HC #1 and 4.5 2.5+/-1 inches of water for HC #2 and the

average outlet chromium concentration is 0.00239 mg/dscm. 

(b) The Permittee is not required to further test tanks HC #1 and HC #2 by this permit. 

However, the IDEM may require testing when necessary to determine if the tanks are in

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

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

with 40 CFR 63.344 and Section C.8 Performance Testing.

(c) Any change, modification, or reconstruction of the tanks HC #1 and HC #2, the packedbed scrubber/composite mesh-pad system, foam blanket-type fume suppressant, and

composite mesh-pad, or monitoring equipment may require additional performance

testing conducted in accordance with 40 CFR 63.344 and Section C.8 Performance

Testing.

D.1.8 Monitoring to Demonstrate Continuous Compliance [326 IAC 2-6.1-5(a)(2)] [326 IAC 20-8-1]

(a) Pursuant to 40 CFR 63.343(c)(3) and 63.343(c)(1)(ii), when using a packed bed

scrubber in conjunction with a composite mesh-pad system to comply with the limit

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,
R&S Plating, INC. First Administrative Amendment Page 4 of 7

Indianapolis, IN. 097-14505-00325 OP No: 097-11695-00325

Permit Reviewer: SLD

the composite mesh-pad system shall be operated within 3.0 2.5 ±1 inchs of water

column of the pressure drop value for HC #1, and within 4.5 2.5 ±1 inchs of water

column of the pressure drop value for HC #2, as established during the initial

performance test.

(b) 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 than

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

D.1.9 Record Keeping Requirements [40 CFR 63.346] [326 IAC 20-8-1]

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.14 General Record Keeping Requirements of this permit and include

a minimum of the following:

(a) Inspection records for the packed-bed scrubber/composite mesh-pad system, foam

blanket-type fume suppressant, and composite mesh-pad system and monitoring equipment to

document that the inspection and maintenance required by Conditions D.1.7 and D.1.9 have

taken place. The record can take the form of a checklist and should identify the following:

(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 packed-bed

scrubber/composite mesh-pad system, foam blanket-type fume suppressant, and

composite mesh-pad, and monitoring equipment.

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

HC #1 and HC #2, the packed-bed scrubber/composite mesh-pad system, foam blankettype fume suppressant, and composite mesh-pad, 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 packed-bed scrubber/composite mesh-pad

system, foam blanket-type fume suppressant, and composite mesh-pad and monitoring

equipment as indicated by monitoring data collected in accordance with this condition.

(e) Records of actions taken during periods of malfunction or excess emissions 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 
R&S Plating, INC. First Administrative Amendment Page 5 of 7

Indianapolis, IN. 097-14505-00325 OP No: 097-11695-00325

Permit Reviewer: SLD

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.1.8(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.

2. Due to errors within the original permit, The Ongoing Compliance Status Report form

was amended to reflect the correct total chromium concentration as 0.03 mg/dscm and

instructions have been inserted in the second table from the bottom of the page which

previously were not included.

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY, COMPLIANCE DATA SECTION

and CITY OF INDIANAPOLIS 

ENVIRONMENTAL RESOURCES MANAGEMENT DIVISION

CHROMIUM ELECTROPLATING NESHAP

ONGOING COMPLIANCE STATUS REPORT

Source Name: R&S Plating, Inc.

Source Address: 2302 Bloyd Ave., Indianapolis, IN 

Mailing Address: 2302 Bloyd Ave., Indianapolis, IN

Part 70 Permit No.: 097-11695-00325

Tank ID #: HC #1 and HC #2

Type of process: Hard

Monitoring Parameter: composite mesh-pad system

Parameter Value: shall be operated within ±1 inch of water column of the pressure drop value

established during the initial performance test

Limits: Total chromium concentration may not exceed .01 0.03mg/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, OAQ, Compliance Branch and ERMD. 

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).
R&S Plating, INC. First Administrative Amendment Page 6 of 7

Indianapolis, IN. 097-14505-00325 OP No: 097-11695-00325

Permit Reviewer: SLD

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

3. According to 326 IAC 2-6.1-5(a)(5) the “authorized individual” must “provide an annual

notice to the department that the source is in operation and compliance with the permit.”

The form that R&S Plating should be using to fulfill the “signed certification” requirement

is listed below as follows:

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY

COMPLIANCE DATA SECTION

AND

INDIANAPOLIS ENVIRONMENTAL RESOURCES MANAGEMENT DIVISION

AIR QUALITY MANAGEMENT SECTION

DATA COMPLIANCE

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: R&S Plating, Inc.

Address: 2302 Bloyd Ave.

City: Indianapolis 

Phone #: (317) 925-2396

MSOP #: 097-11695-00325

I hereby certify that R&S Plating, Inc. is 

9 still in operation. 9 no longer in operation.

I hereby certify that R&S Plating, Inc. is 

9 in compliance with the requirements of MSOP 097-11695-00325.

9 not in compliance with the requirements of MSOP 097-11695-00325.
R&S Plating, INC. First Administrative Amendment Page 7 of 7

Indianapolis, IN. 097-14505-00325 OP No: 097-11695-00325

Permit Reviewer: SLD

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:

4. In response to numeral 8 of the listed requests for administrative amendments submitted

by R&S Plating; 326 IAC 8-3-2 and 326 IAC 8-3-5 of the original permit will remain

included and applicable. However, after consulting with David Farlow of R&S Plating,

on August 9, 2001, an agreement was made so that R&S will comply with whatever

condition is considered the most stringent guideline when comparing Section D.2.1 and

D.2.2 of the permit.

All other conditions of the permit shall remain unchanged and in effect. Please attach a copy of

this amendment and the following revised permit pages to the front of the original permit. 

This decision is subject to the Indiana Administrative Orders and Procedures Act - IC 4-21.5-3-5. 

 If you have any questions on this matter, please contact Scott L. Dombrowski, at (317) 327-2176.

Sincerely,

Original Signed by Vaneeta Kumar

Vaneeta Kumar, Administrator

Indianapolis, ERMD

Attachments-First Administrative Amendment

SLD

cc: file (2 copies)

Mindy Hahn, IDEM OAQ
MINOR SOURCE OPERATING PERMIT

OFFICE OF AIR QUALITY

and 

INDIANAPOLIS ENVIRONMENTAL RESOURCES

MANAGEMENT DIVISION

R&S Plating, Inc.

2302 Bloyd Ave.

Indianapolis, Indiana 46218

(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 097-11695-00325 

Issued by: 

Mona A. Salem

Chief Operationg Officer

Department of Public Works

City of Indianapolis

Issuance Date: September 5, 2000

Expiration Date: September 7, 2005

 

First Administrative Amendment: 097-14505-

00325 

Pages Affected: 1, 4, 14, 15, 16, 17, 18, 24, and 26

Issued by: Original Signed by Vaneeta Kumar

Vaneeta Kumar

Administrator, ERMD

City of Indianapolis

Issuance Date: September 19, 2001
R&S Plating, INC. First Administrative Amendment Page 4 of 29

Indianapolis, IN. 097-14505-00325 OP No: 097-11695-00325

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SECTION A SOURCE SUMMARY

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

(IDEM), Office of Air Quality (OAQ) and the City of Indianapolis Environmental Resources Management

Division (ERMD). The information describing the source contained in conditions A.1 through A.2 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 chrome plating process.

Authorized Individual: J. Michael Raymond

Source Address: 2302 Bloyd Ave., Indianapolis, IN 46218

Mailing Address: 2302 Bloyd Ave., Indianapolis, IN 46218

Phone Number: (317) 925-4939

SIC Code: 3471

County Location: Marion

County Status: Attainment for all criteria pollutants 

Source Status: Minor Source Operating Permit

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 with a maximum cumulative rectifier capacity of

17,640,000 Ampere-hours consisting of: One (1) hard chromium electroplating tank, identified as

HC #1, equipped with a packed-bed scrubber and a composite mesh-pad as a common control,

and exhausting to one (1) stack, identified as Stack 2;

(b) One (1) hard chromium electroplating operation with a maximum cumulative rectifier capacity of

23,520,000 Ampere-hours consisting of: One (1) hard chromium electroplating tank, identified as

HC #2, equipped with a packed-bed scrubber and a composite mesh-pad as a common control,

and exhausting to one (1) stack, identified as Stack 2;

(c) One (1) cold cleaner degreaser, utilizing one (1) gallon of mineral spirits a year, without a remote

solvent reservoir, identified as Mineral Spirits;

(d) One (1) cold cleaner degreaser, utilizing 70 gallons of MEK (2-Butanone) a year, without a remote

solvent reservoir, identified as MEK;

(e) Three (3) natural gas fueled space heaters, with a combined maximum heat input rate of 0.29

million Btu per hour, exhausting to stacks 9, 10, and 8, and identified as Space Heaters;

(f) One (1) natural gas fueled parts bake oven, with a maximum heat input rate of 0.02 million Btu

per hour, identified as Parts Bake Oven;

(g) One natural gas fueled burner, with a maximum heat input rate of 0.02 million Btu per hour,

identified as Burner. 
R&S Plating, INC. First Administrative Amendment Page 14 of 29

Indianapolis, IN. 097-14505-00325 OP No: 097-11695-00325

Permit Reviewer: SLD

SECTION D.1 FACILITY OPERATION CONDITIONS

Facility Description [326 IAC 2-7-5(15)]: Chromium Electroplating Operations

The information describing the process contained in this facility description box is descriptive

information and does not constitute enforceable conditions. 

(a) One (1) hard chromium electroplating operation with a maximum cumulative rectifier capacity

of 17,640,000 Ampere-hours consisting of: One (1) hard chromium electroplating tank,

identified as HC #1, equipped with a packed-bed scrubber and a composite mesh-pad as a

common control, and exhausting to one (1) stack, identified as Stack 2;

(b) One (1) hard chromium electroplating operation with a maximum cumulative rectifier capacity

of 23,520,000 Ampere-hours consisting of: One (1) hard chromium electroplating tank,

identified as HC #2, equipped with a packed-bed scrubber and a composite mesh-pad as a

common control, and exhausting to one (1) stack, identified as Stack 2;

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 HC #1 and HC #2.

D.1.2 Chromium Electroplating and Anodizing 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 HC #1 and HC #2.

D.1.3 Chromium Emissions Limitation [40 CFR 63.342(c)] [40 CFR 63.343(a)(1)&(2)][326 IAC 20-8-1]

(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 tanks HC #1 and HC #2 above,

are 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]. 

D.1.4 Work Practice Standards [40 CFR 63.342(f)] [326 IAC 20-8-1]

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 packedbed scrubber, 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.
R&S Plating, INC. First Administrative Amendment Page 15 of 29

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Permit Reviewer: SLD

(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, OAQ and ERMD, 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, OAQ and ERMD may require that the Permittee make changes to the OMP

required by Condition D.1.6. Revisions may be required if IDEM, OAQ and ERMD finds

that the plan:

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

occurred;

(2) Fails to provide for the operation of tanks HC #1 and HC #2, the packed-bed

scrubber and composite mesh pad, and process monitoring equipment during a

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

pollution control practices; or,

 (3) Does not provide adequate procedures for correcting malfunction process

equipment, packed-bed scrubber and composite mesh pad, and monitoring

equipment or other causes of excess emissions as quickly as practicable.

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 packed-bed scrubber and

composite mesh pad system. 

D.1.6 Operation and Maintenance Plan [40 CFR 63.342(f)(3)] [326 IAC 20-8-1]

(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 packed-bed scrubber

and composite mesh pad, and monitoring equipment shall include the following

elements:

(1) For the packed-bed scrubber/composite mesh-pad system (PBS/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 tank to the control

device to ensure there are no leaks.
R&S Plating, INC. First Administrative Amendment Page 16 of 29

Indianapolis, IN. 097-14505-00325 OP No: 097-11695-00325

Permit Reviewer: SLD

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

manufacturers recommendations.

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

tanks HC #1 and HC #2, the air pollution control technique, packed-bed

scrubber, composite mesh pad, 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, OAQ

and ERMD.

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

available, upon request, by IDEM, OAQ and ERMD 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, OAQ and ERMD for a

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

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]

[326 IAC 20-8-1]

(a) A performance test demonstrating initial compliance for tanks HC #1 and HC #2 was

performed on May 19, 1997. During the initial performance test, it was determined that

the average overall pressure drop across the composite mesh pad system was 3.0 +1

inches of water for HC #1 and 4.5 +1 inches of water for HC #2 and the average outlet
R&S Plating, INC. First Administrative Amendment Page 17 of 29

Indianapolis, IN. 097-14505-00325 OP No: 097-11695-00325

Permit Reviewer: SLD

 chromium concentration is 0.00239 mg/dscm. 

(b) The Permittee is not required to further test tanks HC #1 and HC #2 by this permit. 

However, the IDEM may require testing when necessary to determine if the tanks are in

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

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

with 40 CFR 63.344 and Section C.8 Performance Testing.

(c) Any change, modification, or reconstruction of the tanks HC #1 and HC #2, the packedbed scrubber and composite mesh pad or monitoring equipment may require additional

performance testing conducted in accordance with 40 CFR 63.344 and Section C.8

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)] [326 IAC 20-8-1]

(a) Pursuant to 40 CFR 63.343(c)(3) and 63.343(c)(1)(ii), when using a packed bed

scrubber in conjunction with a composite mesh-pad system to comply with the limit

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 3.0 ±1 inchs of water column

of the pressure drop value for HC #1, and within 4.5 ±1 inchs of water column of the

pressure drop value for HC #2, as established during the initial performance test.

(b) 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. 

Record Keeping and Reporting Requirements [326 IAC 2-6.1-5(a)(2)] [326 IAC 2-8-5(3)

D.1.9 Record Keeping Requirements [40 CFR 63.346] [326 IAC 20-8-1]

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.14 General Record Keeping Requirements of this permit and include

a minimum of the following:

(a) Inspection records for the packed-bed scrubber, composite mesh-pad system and

monitoring equipment to document that the inspection and maintenance required by

Conditions D.1.7 and D.1.9 have taken place. The record can take the form of a

checklist and should identify the following:

(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.
R&S Plating, INC. First Administrative Amendment Page 18 of 29

Indianapolis, IN. 097-14505-00325 OP No: 097-11695-00325

Permit Reviewer: SLD

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

scrubber, and 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 packed-bed scrubber, 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 packed-bed scrubber and 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 or excess emissions 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.1.8(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.1.10.

D.1.10 Reporting Requirements [326 IAC 3-6-4(b)] [40 CFR 63.344(a), 63.345 and 63.347] [326 IAC 20-

8-1]

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

ERMD using the address specified in Section C.15 General Reporting Requirements.

(a) Notifications:

(1) Initial Notifications

The Permittee shall notify IDEM, OAM and ERMD 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. 
R&S Plating, INC. First Administrative Amendment Page 24 of 29

Indianapolis, IN. 097-14505-00325 OP No: 097-11695-00325

Permit Reviewer: SLD

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY, COMPLIANCE DATA SECTION

and CITY OF INDIANAPOLIS 

ENVIRONMENTAL RESOURCES MANAGEMENT DIVISION

CHROMIUM ELECTROPLATING NESHAP

ONGOING COMPLIANCE STATUS REPORT

Source Name: R&S Plating, Inc.

Source Address: 2302 Bloyd Ave., Indianapolis, IN 

Mailing Address: 2302 Bloyd Ave., Indianapolis, IN

Part 70 Permit No.: 097-11695-00325

Tank ID #: HC #1 and HC #2

Type of process: Hard

Monitoring Parameter: composite mesh-pad system

Parameter Value: shall be operated within ±1 inch of water column of the pressure drop value

established during the initial performance test

Limits: Total chromium concentration may not exceed .03 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, OAQ, Compliance Branch and ERMD. 

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
R&S Plating, INC. First Administrative Amendment Page 26 of 29

Indianapolis, IN. 097-14505-00325 OP No: 097-11695-00325

Permit Reviewer: SLD

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY

COMPLIANCE DATA SECTION

AND

INDIANAPOLIS ENVIRONMENTAL RESOURCES MANAGEMENT DIVISION

AIR QUALITY MANAGEMENT SECTION

DATA COMPLIANCE

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: R&S Plating, Inc.

Address: 2302 Bloyd Ave.

City: Indianapolis 

Phone #: (317) 925-2396

MSOP #: 097-11695-00325

I hereby certify that R&S Plating, Inc. is 

9 still in operation. 9 no longer in operation.

I hereby certify that R&S Plating, Inc. is 

9 in compliance with the requirements of MSOP 097-11695-00325.

9 not in compliance with the requirements of MSOP 097-11695-00325.

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: