MINOR SOURCE OPERATING PERMIT

And Certificate of Operation

CITY OF EVANSVILLE

ENVIRONMENTAL PROTECTION AGENCY

And

INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT

OFFICE OF AIR QUALITY

Hard Chrome

510 Dresden

Evansville, Indiana 47710

(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 MCE 3.30 and

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 163-11753-00152

Issued by:

Dona J. Bergman, Director

City of Evansville, EPA

Issuance Date: March 15, 2002
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Permit Reviewer: LJS

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

B GENERAL CONSTRUCTION CONDITIONS

B.1 Permit No Defense [IC 13]

B.2 Definitions

B.3 Effective Date of the Permit [IC 13-15-5-3]

B.4 Modification to Permit [326 IAC 2]

C SOURCE OPERATION CONDITIONS

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

[326 IAC 2-3]

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 2-5.1-3(e)(4)(B)] [326 IAC 2-6.1-5(a)(4)]

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]

C.8 Fugitive Dust Emissions [326 IAC 6-4]

Testing Requirements

C.9 Performance Testing [326 IAC 3-6] [326 IAC 2-1.1-11]

C.10 Monitoring Methods [326 IAC 3]

C.11 Actions Related to Noncompliance Demonstrated by a Stack Test

Record Keeping and Reporting Requirements

C.12 Malfunctions Report [326 IAC 1-6-2]

C.13 Monitoring Data Availability [326 IAC 2-6.1-2] [IC 13-14-1-3]

C.14 General Record Keeping Requirements [326 IAC 2-6.1-2]

C.15 General Reporting Requirements [326 IAC 2-1.1-11][326 IAC 2-6.1-2][IC 13-14-1-13]

C.16 Annual Notification [326 IAC 2-6.1-5(a)(5)]

D.1 EMISSIONS UNIT OPERATION CONDITIONS: hard chrome electroplating

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]

D.1.2 Chromium Electroplating and Anodizing 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)][326 IAC 2-.1-5 (a)(2)]

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

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

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

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

D.1.7 Performance Testing [2-1.1-11]

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

D.1.8 Record Keeping and Reporting Requirements [326 IAC 2-6.1-5(a)(2)]

D.1.9 Reporting Requirements [326 IAC 3-6-4(b)][40 CFR 63.344(a), 63.345 & 63.347]
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Malfunction Report

Chromium Electroplating NESHAP Ongoing Compliance Status Report

Annual Report

SECTION A SOURCE SUMMARY
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This permit is based on information requested by the Indiana Department of Environmental Management

(IDEM), Office of Air Management (OAQ). 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 chromium electroplating source.

Authorized Individual: Bob Oglesby

Source Address: 510 Dresden, Evansville, IN 47710

Mailing Address: 510 Dresden, Evansville, IN 47710

Phone Number: 812-422-2855

SIC Code: 3471

County Location: Vanderburgh

County Status: Attainment area for all criteria pollutants

Source Status: Minor Source Operating Permit

Minor Source, under PSD and Emission Offset 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:

One (1) Hard Chromium Electroplating Operation with a maximum cumulative rectifier capacity

of 288,120,000 Ampere-hours consisting of:

Ten (10) hard chromium electroplating tanks, identified as Tanks #s 1 (Rectifier 14: 2000

amps), 2 (Rectifier 15: 3000 amps), 3 (Rectifier 4: 8000 amps and Rectifier 5: 10,000

amps), 4 (Rectifier 6: 10,000 amps and Rectifier 7 8000 amps), 5 (Rectifier 8: 8000

amps), 6 (Rectifier 9: 10,000 amps), 7 (Rectifier 12: 8000 amps), 8 (Rectifier 13: 8000

amps) , 9 (Rectifier 11: 8000 amps), and 10 (Rectifier 10: 8000 amps), equipped with two

(2) packed bed scrubbers and one composite mesh pad scrubber. Tanks 3 and 4 exhaust to

PBS #1 and tanks 1, 2, 5, 6, 7, 8, 9, and 10 exhaust to PBS #2. Both packed bed

scrubbers exhaust to the common composite mesh pad.

One (1) Bryant natural gas boiler rated at 1.56 mmbtu/hr

SECTION B GENERAL CONDITIONS
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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 operate 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

there under, 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 [IC 13-15-5-3]_______________________________________

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

B.4 Modification to Permit [326 IAC 2]______________________________________________

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

a manner consistent with procedures established for modifications of operating permits pursuant

to 326 IAC 2 (Permit Review Rules).

SECTION C SOURCE OPERATION CONDITIONS
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Entire Source

C.1 PSD and Emission Offset Minor Source Status [326 IAC 2-2] [40 CFR 52.21] [326 IAC 2-3]

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

and the potential to emit of VOC and NOX are less than 25 tons per year. Therefore the

requirements of 326 IAC 2-2 (Prevention of Significant Deterioration), 326 IAC 2-3

(Emission Offset) and 40 CFR 52.21 will not apply.

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

tons per year, 10 tons per year of any single hazardous air pollutant, twenty-five tons per

year of any combination of hazardous air pollutants, or 100 tons per year of any other

regulated pollutant from this source, shall cause this source to be considered a major

source under Part 70 Permit Program, 326 IAC 2-7, and shall require approval from

IDEM, OAQ AND EVANSVILLE EPA 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, OAQ, and City of Evansville EPA upon request and

shall be subject to review and approval by IDEM, OAQ and City of Evansville EPA.

IDEM, OAQ, and City of Evansville EPA 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.

(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 Quality

100 North Senate Avenue, P.O. Box 6015

Indianapolis, Indiana 46206-6015

AND
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City of Evansville Environmental Protection Agency

101 Court Street

Riverside One Bldg. Suite 205

Evansville, IN 47708

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 OAQ 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 2-5.1-3(e)(4)(B)] [326 IAC 2-6.1-5(a)(4)]________________

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, OAQ AND EVANSVILLE EPA, U.S. EPA, or an

authorized representative to perform the following:

(a) Enter upon the Permittee's premises where a Part 70 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 the conditions of this permit;

(c) Inspect, at reasonable times, any facilities, equipment (including monitoring and

air pollution control equipment), practices, or operations regulated or required

under this permit;

(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.

(1) The Permittee may assert a claim that, in the opinion of the Permittee,

information removed or about to be removed from the source by IDEM,

OAQ AND EVANSVILLE EPA, or an authorized representative,

contains information that is confidential under IC 5-14-3-4(a). The claim

shall be made in writing before or at the time the information is removed

from the source. In the event that a claim of confidentiality is so asserted,

neither IDEM, OAQ AND EVANSVILLE EPA, nor an authorized

representative, may disclose the information unless and until IDEM,

OAQ AND EVANSVILLE EPA, makes a determination under 326 IAC

17-1-7 through 326 IAC 17-1-9 that the information is not entitled to

confidential treatment and that determination becomes final. [IC 5-14-3-

4; IC 13-14-11-3; 326 IAC 17-1-7 through 326 IAC 17-1-9]

(2) The Permittee, and IDEM, OAQ AND EVANSVILLE EPA,

acknowledge that the federal law applies to claims of confidentiality

made by the Permittee with regard to information removed or about to be

removed from the source by U.S. EPA. [40 CFR Part 2, Subpart B]
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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,

OAQ, Permits Branch, and City of Evansville EPA 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) City of Evansville EPA, 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.

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

Pursuant to 326 IAC 2-1-9(a)(Revocation of Permits), this permit to 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 forty percent (40%) 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.

C.8 Fugitive Dust Emissions [326 IAC 6-4]___________________________________________

The Permittee shall not allow fugitive dust to escape beyond the property line or boundaries of

the property, right-of-way, or easement on which the source is located, in a manner that would

violate 326 IAC 6-4 (Fugitive Dust Emissions). 326 IAC 6-4-2(4) is not federally enforceable.

Testing Requirements
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C.9 Performance Testing [326 IAC 3-6][326 IAC 2-1.1-11]______________________________

(a) 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 methods

approved by IDEM, OAQ.

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 Quality

100 North Senate Avenue, P. O. Box 6015

Indianapolis, Indiana 46206-6015

AND

City of Evansville Environmental Protection Agency

101 Court Street

Riverside One Bldg. Suite 205

Evansville, IN 47708

at least sixty (60) days before the intended test date for all chromium electroplating

facilities and no later than thirty-five (35) days prior to the intended test date for all other

facilities. The Permittee shall submit a notice of the actual test date to the above address

so that it is received at least two (2) weeks prior to the test date.

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

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

submits to IDEM, OAQ, 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.10 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.11 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, OAQ, and City of Evansville

Environmental Protection Agency 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, OAQ 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,

OAQ within thirty (30) days of receipt of the notice of deficiency. IDEM, OAQ reserves

the authority to use enforcement activities to resolve noncompliant stack tests.
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(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,

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

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.

Record Keeping and Reporting Requirements

C.12 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 (OAQ), EEPA 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 OAQ and EEPA, 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.13 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.
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(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.

(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.14 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, OAQ, or EEPA 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 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.

C.15 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 Semi-annual 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).
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(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

AND

City of Evansville Environmental Protection Agency

101 Court Street

Riverside One Bldg. Suite 205

Evansville, IN 47708

(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, OAQ, on or before the date it is due.

(d) Unless otherwise specified in this permit, any semi-annual 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.
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C.16 Annual Notification [326 IAC 2-6.1-5(a)(5)]_____________________________________

(a) Annual notification shall be submitted to the Office of Air Quality and EEPA 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

AND

City of Evansville Environmental Protection Agency

101 Court Street

Riverside One Bldg. Suite 205

Evansville, IN 47708

(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, OAQ, and EEPA on or before the date it is due.

SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS
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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 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 1, 2, 3, 4, 5, 6, 7, 8,

9, & 10. 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)][326 IAC 20-8-1] [326

IAC 2-6.1-5(a)(2)]

(a) The emission limitations in the 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 # 1, 2, 3, 4, 5, 6, 7, 8, 9 &10

above, are considered a large, existing 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 [6.6 x 10-6

gr/dscf].

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

with the limit specified in this condition, 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.

Emissions Unit Description:

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

information and does not constitute enforceable conditions.

One (1) Hard Chromium Electroplating Operation with a maximum cumulative rectifier capacity of

288,120,000 Ampere-hours consisting of:

 Ten (10) hard chromium electroplating tanks, identified as Tanks #s 1 (Rectifier 14: 2000

amps), 2 (Rectifier 15: 3000 amps), 3 (Rectifier 4: 8000 amps and Rectifier 5: 10,000 amps), 4

(Rectifier 6: 10,000 amps and Rectifier 7 8000 amps), 5 (Rectifier 8: 8000 amps), 6 (Rectifier 9:

10,000 amps), 7 (Rectifier 12: 8000 amps), 8 (Rectifier 13: 8000 amps) , 9 (Rectifier 11: 8000 amps),

and 10 (Rectifier 10: 8000 amps), equipped with two (2) packed bed scrubbers and one composite

mesh pad scrubber. Tanks 3 and 4 exhaust to PBS #1, tanks 1, 2, 5, 6, 7, 8, 9, and 10 exhaust to PBS

#2. Both packed bed scrubbers exhaust to the common composite mesh pad.
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Permit Reviewer: LJS

(d) Pursuant to 40 CFR 63.343 (c)(2)(ii), when using a packed-bed scrubber to comply with

the limit specified in this condition, the Permittee shall monitor and record the velocity

pressure at the inlet to the packed-bed scrubber system during tank operation once each

day that the hard chromium electroplating tank is operating. To be in compliance with

the standards, the scrubber system shall be within + 10 percent of the velocity pressure

value established during the initial performance test, and within + 1 inch of the 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.1.4 Work Practice Standards [40 CFR 63.342 (f)][326 IAC 20-8-1]___________________________

The following work practice standards apply to tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10:

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

the Permittee shall operate and maintain tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10, including the

packed-bed scrubbers and the 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, OAQ and Evansville EPA, 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 Evansville EPA may require that the Permittee make changes to the

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

Evansville EPA 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 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10, the

packed-bed scrubbers, or the 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) Does not provide adequate procedures for correcting malfunctioning process

equipment, packed-bed scrubbers, 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.
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Evansville, IN MSOP 163-11753-00152

Permit Reviewer: LJS

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

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

Maintenance Plan, of this permit, is required for the tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10 and the

packed-bed scrubbers.

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 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10, the

packed-bed scrubbers, the composite mesh pad system and monitoring equipment shall

include the following elements:

(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 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) For the packed-bed scrubber (PBS):

(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 inspections of the back portion of the chevron blade

mist eliminator to ensure that it is dry and 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) Add fresh makeup water to the top of the packed bed if greater than 50%

of the scrubber water is drained.

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

tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10, the air pollution control device, the add-on air

pollution control device and the monitoring equipment.

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

to poor maintenance or other preventable conditions or periods of excess

emissions are indicated by monitoring data do not occur.

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

emissions of tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10; packed bed scrubber #1, packed
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Evansville, IN MSOP 163-11753-00152

Permit Reviewer: LJS

bed scrubber # 2 and the composite mesh pad; 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 of the plan

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 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10; packed bed scrubber #1, packed bed

scrubber # 2 and the composite mesh pad, during similar malfunction or period of excess

emissions events, and 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 Evansville EPA.

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

available, upon request, by IDEM OAQ or Evansville EPA for the life of the tanks 1, 2,

3, 4, 5, 6, 7, 8, 9, & 10 and packed bed scrubber #1, packed bed scrubber # 2 and the

composite mesh pad 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 or

Evansville EPA 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]_______________________________________

(a) A performance test demonstrating initial compliance for tanks, 1, 2, 3, 4,

5, 6, 7, 8, 9, & 10 was performed on June 16, 1997. It was determined that the average

pressure drop across the composite mesh pad system was 1.00 inches of water and the

average outlet chromium concentration is 0.0031 mg/dscm. Also during that test, it was

determined that the average pressure drop across the pack bed scrubber system 1(PB1)

was 1.73 inches of water and for the pack bed scrubber system 2 (PB2) was 1.7 inches of

water with total chromium concentration not exceeding 0.015 mg/dscm. The inlet

velocity is 710 fpm and 800fpm respectively.

(b) The Permittee is not required to further test tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10 by this

permit. However, the IDEM may require testing when necessary to determine if the tank

1-10 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.9 - Performance Testing.

(c) Any change, modification, or reconstruction of the tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10, the

packed-bed scrubbers, the composite mesh pad system monitoring equipment or

monitoring equipment may require additional performance testing conducted in
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Evansville, IN MSOP 163-11753-00152

Permit Reviewer: LJS

accordance with 40 CFR 63.344 and Section C.9 - Performance Testing.

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

D.1.8 Record Keeping and Reporting Requirements [326 IAC 2-6.1-5(a)(2)]____________

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

D.1.6. 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 two (2) packed bed scrubbers and one composite mesh pad

scrubber and monitoring equipment to document that the inspection and maintenance

required by Conditions D.1.6 and D.1.7 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 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10, the two (2)

packed bed scrubbers and one composite mesh pad scrubber and monitoring equipment.

(c) Records of the occurrence, duration, and cause (if known) of each malfunction of tanks 1,

2, 3, 4, 5, 6, 7, 8, 9, & 10 the two (2) packed bed scrubbers and one composite mesh pad

scrubber and monitoring equipment.

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

emissions of tanks 1, 2, 3, 4, 5, 6, 7, 8, 9 & 10, the two (2) packed bed scrubbers and one

composite mesh pad scrubber 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.
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Evansville, IN MSOP 163-11753-00152

Permit Reviewer: LJS

(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.1.9 Reporting Requirements [326 IAC 3-6-4 (b)][40 CFR 63.344(a), 63.345 & 63.347][326 IAC 20-8-1]_____

The notification and reports required in this section shall be submitted EEPA and IDEM, OAQ

using the addresses specified in Section C – General Reporting Requirements.

(a) Notifications:

(1) Initial Notifications

The Permittee shall notify EEPA and IDEM, OAQ 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 EEPA and IDEM, OAQ and shall list, for

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

(B) The NCS for tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10 was submitted to IDEM,

OAQ.

(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, OAQ. In addition, the Permittee may not

change, modify, or reconstruct tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10 without

submitting a Notification of Construction or Reconstruction (NCR) to IDEM,

OAQ.

(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 1, 2, 3, 4, 5, 6, 7, 8,

9, & 10 serves as this notification.
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Permit Reviewer: LJS

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

and IDEM, OAQ before construction, modification, or reconstruction

may commence.

(b) Performance Test Results

The Permittee shall document results from 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.

(c) Ongoing Compliance Status Report

The Permittee shall prepare summary reports to document the ongoing compliance status

of tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10 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 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10 are located at a 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, OAQ and EEPA 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 issuance date of this

permit 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 both of the following conditions are met, semiannual reports shall be prepared

and submitted to EEPA and IDEM, OAQ:

(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, OAQ or EEPA 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.
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Evansville, Indiana MSOP 163-11753-00152

Permit Reviewer: LJS

MALFUNCTION REPORT

EVANSVILLE ENVIRONMENTAL PROTECTION AGENCY

FAX NUMBER – 812-435-6155

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY

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 ?_____, 100 TONS/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: ___Hard Chrome______ PHONE NO. : 812-422-2356

LOCATION: (CITY AND COUNTY) Evansville / Vanderburgh____________________________________________________________

PERMIT NO. 163-11753 AFS PLANT ID: 163-00152 AFS POINT ID:______________________ INSP:_____________________

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
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Evansville, Indiana MSOP 163-11753-00152

Permit Reviewer: LJS

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
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Evansville, Indiana MSOP 163-11753-00152

Permit Reviewer: LJS

CITY OF EVANSVILLE ENVIRONMENTAL PROTECTION AGENCY

AND

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION

CHROMIUM ELECTROPLATING NESHAP

ONGOING COMPLIANCE STATUS REPORT

(Complete this form for each affected tank)

Source Name: Hard Chrome

Source Address: 510 Dresden, Evansville, Indiana 47710

Mailing Address: 510 Dresden, Evansville, Indiana 47710

MSOP No.: 163-11753-00152

Tank ID #: __________________________________

Type of process: Hard

Monitoring Parameter: Surface tension of the electroplating bath

Parameter Value: 45 dynes per centimeter

Limits: Total chromium concentration may not exceed _0.015_ 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.

Complete this report no later than 30 days after the end of the reporting period , and retain of 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

 NO DEVIATIONS OF THE MONITORING PARAMETER ASSOCIATED WITH THIS TANK FROM THE

COMPLIANT VALUE OR RANGE OF VALUES OCCURRED DURING THIS REPORTING PERIOD.

 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
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Permit Reviewer: LJS

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

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.

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.
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Evansville, Indiana MSOP 163-11753-00152

Permit Reviewer: LJS

CITY OF EVANSVILLE ENVIRONMENTAL PROTECTION AGENCY

AND

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY

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: Hard Chrome

Address: 510 Dresden

City: Evansville, Indiana 47710

Phone #: 812-422-2356

MSOP #: 163-11753-00152

I hereby certify that Hard Chrome is  still in operation.

no longer in operation.

I hereby certify that Hard Chrome is in compliance with the requirements of

MSOP 163-11753-00152

not in compliance with the requirements of

MSOP 163-11753-00152.

Authorized Individual (typed): Bob Oglesby

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:
Indiana Department of Environmental Management

Office of Air Quality

Addendum to the

Technical Support Document for Minor Source Operating Permit

Hard Chrome

510 Dresden, Evansville, IN 47710

MSOP 163-11753, Plt ID 000152

On February 8, 2002, the Evansville Environmental Protection Agency (EEPA) had a notice

published in the Courier Press, Evansville, Indiana, stating that Hard Chrome had applied for a

Minor Source Operating Permit to operate a chromium electroplating facility. The notice also stated

that EEPA proposed to issue a permit for this operation and provided information on how the public

could review the proposed 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.

The EEPA and the Indiana Department of Environmental Management (IDEM) have decided

to make the following changes:

Change 1:

Section D.1 has been changed as follows:

Ten (10) hard chromium electroplating tanks, identified as Tanks #s 1 (Rectifier 14: 2000 amps),

2 (Rectifier 15: 3000 amps), 3 (Rectifier 4: 8000 amps and Rectifier 5: 10,000 amps), 4

(Rectifier 6: 10,000 amps and Rectifier 7 8000 amps), 5 (Rectifier 8: 8000 amps), 6 (Rectifier

9: 10,000 amps), 7 (Rectifier 12: 8000 amps), 8 (Rectifier 13: 8000 amps) , 9 (Rectifier 11:

8000 amps), and 10 (Rectifier 10: 8000 amps), equipped with two (2) packed bed scrubbers and

one composite mesh pad scrubber. Tanks 3 and 4 exhaust to PBS #1, tanks 1, 2, 5, 6, 7, 8, 9,

and 10 exhaust to PBS #2. Both packed bed scrubbers exhaust to the common composite

mesh pad.

Change 2:

Section D.1.6(a) has been changed as follows:

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

implemented no later than the startup date of tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10, the packed-bed

scrubbers, the composite mesh pad system and monitoring equipment and shall include the

following elements:

Change 3:

Section D.1.6(a)(5) has been changed as follows:
Hard Chrome Page 2 of 3

Evansville, Indiana MSOP 163-11753-00152

Permit Reviewer: LJS

A systematic procedure for identifying malfunctions and periods of excess emissions of

tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10; the air pollution control device, the add-on air pollution

control device packed bed scrubber #1, packed bed scrubber # 2 and the composite

mesh pad; and for implementing corrective actions to address such malfunctions and

periods of excess emissions.

Change 4:

Section D.1.6(c) has been changed as follows:

(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 of the plan

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 1, 2, 3, 4, 5, 6, 7, 8, 9, & 10; the air pollution control device, the add-on

air pollution control device packed bed scrubber #1, packed bed scrubber # 2 and the

composite mesh pad, during similar malfunction or period of excess emissions events,

and program for corrective action for such events.

Change 5:

Section D.1.6(f) has been changed as follows:

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

 available, upon request, by IDEM OAQ or Evansville EPA for the life of the tanks 1, 

 2, 3, 4, 5, 6, 7, 8, 9, & 10 and packed bed scrubber #1, packed bed scrubber # 2 

and the composite mesh pad or until the tank is no longer subject to the provisions 

of 40 CFR 63.340. 

Change 6:

Section D.1.7(a) has been changed as follows:

A performance test demonstrating initial compliance for tanks, 1, 2, 3, 4, 5, 6, 7, 8, 9, &

10 was performed on June 16, 1997. It was determined that the average pressure drop

across the composite mesh pad system was 1.00 inches of water and the average outlet

chromium concentration is 0.0031 mg/dscm. Also during that test, it was determined that

the average pressure drop across the pack bed scrubber system 1(PB1) was 1.73 + inches

of water and for the pack bed scrubber system 2 (PB2) was 1.7 + inches of water with total

chromium concentration not exceeding 0.015 mg/dscm. The inlet velocity for PB 1 was

670 fpm and 800 fpm for PB 2. The inlet velocity is 710 fpm and 800fpm respectively.

Change 7:

Section D.1.8 has been changed as follows:

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.
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Evansville, Indiana MSOP 163-11753-00152

Permit Reviewer: LJS

Change 8:

To be consistent, the changes made to the facility description in Section D were also made to Section

A.2. It now reads as the following:

One (1) Hard Chromium Electroplating Operation with a maximum cumulative rectifier capacity

of 288,120,000 Ampere-hours consisting of:

 Ten (10) hard chromium electroplating tanks, identified as Tanks #s 1 (Rectifier 14: 2000 amps),

2 (Rectifier 15: 3000 amps), 3 (Rectifier 4: 8000 amps and Rectifier 5: 10,000 amps), 4

(Rectifier 6: 10,000 amps and Rectifier 7 8000 amps), 5 (Rectifier 8: 8000 amps), 6 (Rectifier

9: 10,000 amps), 7 (Rectifier 12: 8000 amps), 8 (Rectifier 13: 8000 amps) , 9 (Rectifier 11:

8000 amps), and 10 (Rectifier 10: 8000 amps), equipped with two (2) packed bed scrubbers and

one composite mesh pad scrubber. Tanks 3 and 4 exhaust to PBS #1, tanks 1, 2, 5, 6, 7, 8, 9,

and 10 exhaust to PBS #2. Both packed bed scrubbers exhaust to the common composite

mesh pad.

 
City of Evansville Environmental Protection Agency

and

Indiana Department of Environmental Management

Office of Air Quality

Technical Support Document (TSD) for a Minor Source Operating Permit

Source Background and Description

Source Name: Hard Chrome

Source Location: 510 Dresden, Evansville, Indiana 47710

County: Vanderburgh

SIC Code: 3471

Operation Permit No.: MSOP 163-11753-00152

Permit Reviewer: Leslie J. Sams

The Evansville Environmental Protection Agency (EEPA) has reviewed an application from Hard

Chrome relating to the operation of a chromium electroplating source.

Permitted Emission Units and Pollution Control Equipment

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

emission units and control devices that did not require permits under 326 IAC 2-1, but require

permits under 326 IAC 2-5 and 326 IAC 2-6:

(a) One (1) Hard Chromium Electroplating Operation with a maximum cumulative rectifier

capacity of 288,120,000 Ampere-hours consisting of:

Ten (10) hard chromium electroplating tanks, identified as Tanks #s 1, 2, 3, 4, 5, 6, 7, 8,

9, and 10, equipped with two (2) packed bed scrubbers and one composite mesh pad

scrubber.

(b) One (1) Bryant natural gas boiler rated at 1.56 mmbtu/hr

Unpermitted Emission Units and Pollution Control Equipment

There are no unpermitted facilities operating at this source during this review process.

New Emission Units and Pollution Control Equipment

There are no proposed new facilities at this source during this review process.

Existing Approvals

Hard Chrome has been operating under a City of Evansville Certificate of Operation.
Hard Chrome Page 2 of 6

Evansville, Indiana MSOP 163-11753-00152

Permit Reviewer: LJS

STACK ID OPERATION HEIGHT

(FEET)

DIAMETER

(FEET)

FLOW RATE

(ACFM)

TEMPERATURE

(°F)

#s 1-10 Chrome plating

tank

32.0 2.125 3800 90

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. An application for the purposes of this review

was received on January 12, 2001.

Emission Calculations

Chromium emissions (Single HAP) from the biggest chromium electroplating source in Indiana

are less than ten (10) tons per year and Hard Chrome is a much smaller source in comparison.

Therefore, no emission calculations were necessary for the chromium electroplating

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

Tank Operation or Operating Time

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.

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/YR)

PM 10 0.08

SO2 0.004

VOC 0.04

CO 0.14

NOx 0.65
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Evansville, Indiana MSOP 163-11753-00152

Permit Reviewer: LJS

HAPS POTENTIAL TO EMIT

(TONS/YR)

Chromium < 10

(a) The potential to emit (as defined in 326 IAC 2-7-1(29)) of each pollutant is less than 250

tons per year and the potentials to emit VOC and NOX are less than twenty-five (25) tons

per year. Therefore, the source is not subject to the provisions of 326 IAC 2-7.

(b) 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.

(c) The existing source is subject to 326 IAC 20-8 but not subject to 326 IAC 2-5.5-1(b)(2),

Registration, because the source is not a decorative coating plant. The source is a hard

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

(a) and (b) above). Pursuant to 326 IAC 2-6.1-2, which uses the applicability of 326 IAC

2-5.1-3 (a)(2)(A), the source is required to have an MSOP.

Actual Emissions

No previous emission data has been received from the source.

Potential to Emit

The table below summarizes the total potential to emit, reflecting all limits, of the significant emission

units.

POTENTIAL TO EMIT

(TONS/YR)

Process/facility PM 10 SO2 VOC CO NOx HAP

Bryant boiler 0.08 0.004 0.04 0.14 0.65 0

Chrome line tanks 1-10 0.00 0.00 0.00 0.00 0.00 <10

County Attainment Status

The source is located in Vanderburgh County.

POLLUTANT STATUS

PM 10 Attainment

SO2 Attainment

NO2 Attainment

Ozone Attainment

CO Attainment

Lead Attainment

(a) Vanderburgh County has been classified as attainment or unclassifiable for all criteria

pollutants. Therefore, these emissions were reviewed pursuant to the requirements for

Prevention of Significant Deterioration (PSD), 326 IAC 2-2 and 40 CFR 52.21.
Hard Chrome Page 4 of 6

Evansville, Indiana MSOP 163-11753-00152

Permit Reviewer: LJS

(b) Fugitive Emissions

Since this type of operation is not one of the 28 listed source categories under 326 IAC 2-2,

40 CFR 52.21, or 326 IAC 2-3 and since there are no applicable New Source Performance

Standards that were in effect on August 7, 1980, the fugitive particulate matter (PM) and

volatile organic compound (VOC) emissions are not counted toward determination of PSD

and Emission Offset applicability.

Source Status

Existing Source PSD Definition (emissions after controls, based on 8,760 hours of operation per

year at rated capacity and/ or as otherwise limited):

POLLUTANT POTENTIAL TO EMIT

(TONS/YR)

PM 10 0.08

SO2 0.004

VOC 0.04

CO 0.14

NOx 0.65

 (a) This existing source is not a major stationary source because no attainment regulated

pollutant is emitted at a rate of 250 tons per year or more, and it is not in one of the 28 listed

source categories.

(b) These emissions were based on the potential to emit of the entire source after controls.

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) VOC and NOX are less than 25 tons per year,

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

(d) any combination of HAPS is less than 25 tons/year.

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 provisions of 40 CFR 63 Subpart A - General Provisions, which are incorporated as

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

specified in 40 CFR 63 Subpart N.

(c) The hard chrome electroplating tanks, identified as Tanks 1-10, are subject to the

National Emission Standards for Hazardous Air Pollutants (NESHAPs), 326 IAC 14, (40
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Evansville, Indiana MSOP 163-11753-00152

Permit Reviewer: LJS

CFR 63, Subpart N, and 326 IAC 20-8-1). Pursuant to 40 CFR 63, Subpart N, and 326

IAC 20-8-1, the tanks are subject to the following conditions:

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

gas stream discharged to the atmosphere from the tanks to exceed 0.015 milli-grams

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

(6.6 x 10-6 grains per dry standard cubic foot (gr/dscf)).

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

(3) shall be prepared and maintained and shall specify the operation and mainten-ance

criteria for the tanks, the composite mesh pad system/ packed bed scrubbers

and monitoring equipment.

(c) The Permittee shall submit summary reports to document the ongoing compliance

status of the tanks using the Ongoing Compliance Status Report form. This report

shall contain the information in 40 CFR 63.347(g)(3) that is applicable.

(1) This report must be completed semiannually on a calendar year basis,

unless otherwise directed by IDEM, OAQ. The report shall be submitted

within thirty (30) days after the end of each reporting period (which ends on

June 30 and December 31, respectively) to the address listed in Section

C - General Reporting Requirements.

(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.

(d) Performance tests demonstrating initial compliance for the tanks were performed

on June 16, 1997.

(1) The Permittee shall monitor and record the pressure drop across the composite

mesh pad system/ packed bed scrubbers once each day that the corresponding

tanks are in operation.

 (2) The composite mesh pad system/ packed bed scrubber exhausting to the stack

shall be operated within 1 inches of water column, the pressure drop value

established during the initial performance tests, or shall be operated within the

range of compliant values for pressure drop established during multiple

performance tests that may be conducted in the future.

State Rule Applicability - Entire Source

326 IAC 2-4.1

This chrome electroplating operation will emit less than 10 tons per year of a single HAP and less

than 25 tons per year of a combination of HAPs. Therefore this rule will not apply.

326 IAC 2-6 (Emission Reporting)
Hard Chrome Page 6 of 6

Evansville, Indiana MSOP 163-11753-00152

Permit Reviewer: LJS

This source is located in Vanderburgh County and the potential to emit VOC and NOX is less

than ten (10) tons per year. The potential to emit PM10 is less than one-hundred (100) 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 alternative opacity limitations), opacity shall meet the following, unless otherwise

stated in this permit:

(a) Opacity shall not exceed an average of thirty percent (30%) 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.

Conclusion

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

attached proposed Minor Source Operating Permit 163-11753-00152.