NEW SOURCE CONSTRUCTION PERMIT

and MINOR SOURCE OPERATING PERMIT

OFFICE OF AIR MANAGEMENT

Roembke Manufacturing and Design

1580 Baker Drive

Ossian, Indiana 46777

(herein known as the Permittee) is hereby authorized to construct and 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 2-5.1, 326 IAC 2-6.1 and 40 CFR 52.780, with conditions listed on the attached pages.

Operation Permit No.: MSOP 179-11704-00027

Issued by:

Paul Dubenetzky, Branch Chief

Office of Air Management

Issuance Date:
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TABLE OF CONTENTS

A SOURCE SUMMARY .......................................................... 4

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

A.2 Emission Units and Pollution Control Equipment Summary

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

B GENERAL CONSTRUCTION CONDITIONS ....................................... 5

B.1 Permit No Defense [IC 13]

B.2 Definitions

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

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

B.5 Modification to Permit [326 IAC 2]

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

C SOURCE OPERATION CONDITIONS ............................................ 7

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

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]

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

C.10 Compliance Monitoring [326 IAC 2-1.1-11]

C.11 Monitoring Methods [326 IAC 3]

C.12 Compliance Monitoring Plan - Failure to Take Response Steps [326 IAC 1-6]

C.13 Actions Related to Noncompliance Demonstrated by a Stack Test

Record Keeping and Reporting Requirements

C.14 Malfunctions Report [326 IAC 1-6-2]

C.15 Monitoring Data Availability [326 IAC 2-6.1-2] [IC 13-14-1-3]

C.16 General Record Keeping Requirements [326 IAC 2-6.1-2]

C.17 General Reporting Requirements [326 IAC 2-1.1-11] [326 IAC 2-6.1-2] [IC 13-14-1-13]

C.18 Annual Notification [326 IAC 2-6.1-5(a)(5)]

D.1 EMISSIONS UNIT OPERATION CONDITIONS: Chromium Electroplating ............... 15

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)]

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)]

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

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

63.7] [40 CFR 63.344]

D.1.8 Establishing Site-Specific Operating Parameter Values [40 CFR 63.343(c)] [40 CFR

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

D.1.9 Monitoring to Demonstrate Continuous Compliance [326 IAC 2-5.1-3(e)(2)] [326 IAC

2-6.1-5(a)(2)] [40 CFR 63.343(c)]

Record Keeping and Reporting Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2)]

D.1.10 Record Keeping Requirements [326 IAC 2-5.1-3(e)(2)] [40 CFR 63.346]

D.1.11 Reporting Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 3-6-4(b)] [40 CFR 63.344(a)]

[40 CFR 63.345] [40 CFR 63.347]

Chromium Electroplating NESHAP Ongoing Compliance Status Report .................... 22

Malfunction Report ................................................................ 24

Annual Report .................................................................... 26
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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 Management (OAM). The information describing the source contained in conditions

A.1 and 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 stationary small, hard chromium electroplating source.

Authorized Individual: Martin F. Adam, Jr.

Source Address: 1580 Baker Drive, Ossian, Indiana 46777

Mailing Address: 1580 Baker Drive, Ossian, Indiana 46777

Phone Number: 219 - 622 - 4135

SIC Code: 3470

County Location: Wells

County Status: Attainment for all criteria pollutants

Source Status: Minor Source Operating Permit

Minor Source, under PSD Rules;

Minor Source, Section 112 of the Clean Air Act

A.2 Emissions units and Pollution Control Equipment Summary 

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

pollution control devices:

(a) One (1) chrome plating tank, identified as Tank 1, controlled with a composite mesh pad

system, and exhausting to stack S/V 1, maximum cumulative rectifier capacity: 29,400,000

ampere hours per year.

(b) One (1) chrome plating tank, identified as Tank 2, controlled with a composite mesh pad

system, and exhausting to stack S/V 1, maximum cumulative rectifier capacity: 11,760,000

ampere hours per year.

(c) One (1) space heater, identified as H1, fired by natural gas, heat input capacity: 0.125

million British thermal units per hour.

(d) One (1) space heater, identified as H2, fired by natural gas, heat input capacity: 0.1 million

British thermal units per hour.
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SECTION B GENERAL CONSTRUCTION CONDITIONS

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

40 CFR 52.780, WITH CONDITIONS LISTED BELOW.

B.1 Permit No Defense [IC 13]

This permit to construct does not relieve the Permittee of the responsibility to comply with the provisions of the Indiana Environmental Management Law (IC 13-11 through 13-20; 13-22 through 13-

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

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

B.2 Definitions

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

In the absence of definitions in the referenced regulation, any applicable definitions found in IC 13-

11, 326 IAC 1-2, and 326 IAC 2-1.1-1 shall prevail.

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

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

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

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

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

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

B.5 Modification to Permit [326 IAC 2]

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

and conditions of this construction permit shall remain in effect unless modified in a manner consistent with procedures established for modifications of construction permits pursuant to 326 IAC 2

(Permit Review Rules).

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

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

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

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

(OAM), Permit Administration & Development Section.

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

Permit were constructed as proposed in the application, then the facilities may

begin operating on the date the Affidavit of Construction is postmarked or hand

delivered to IDEM.

(2) If the Affidavit of Construction does not verify that the facilities covered in this Construction Permit were constructed as proposed in the application, then the Permittee

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

Administration & Development Section prior to beginning operation of the facilities.

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

a separate affidavit must be submitted for each phase of construction. Any permit conditions associated with operation start up dates such as stack testing for New Source

Performance Standards (NSPS) shall be applicable to each individual phase.

(c) Upon receipt of the Operation Permit Validation Letter from the Chief of the Permit Administration & Development Section, the Permittee shall attach it to this document.
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(d) The operation permit will be subject to annual operating permit fees pursuant to 326 IAC

2-1.1-7(Fees).

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

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

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

the permit renewal prior to the expiration date of this permit, this existing permit shall not

expire and all terms and conditions shall continue in effect until the renewal permit has been

issued or denied. The operation permit issued shall contain as a minimum the conditions

in Section C and Section D of this permit.
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SECTION C SOURCE OPERATION CONDITIONS

Entire Source

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

The total source potential to emit of each criteria pollutant is less than 250 tons per year. Therefore

the requirements of 326 IAC 2-2 (Prevention of Significant Deterioration) and 40 CFR 52.21 will not

apply.

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

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

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

the following information on each emissions unit:

(1) Identification of the individual(s) responsible for inspecting, maintaining, and repairing emission control devices;

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

schedule for said items or conditions; 

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

inventory for quick replacement.

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

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

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

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

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

Maintenance Plan whenever lack of proper maintenance causes or contributes to any

violation.

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

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

Permittee seeks to amend or modify this permit.

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

to:

Indiana Department of Environmental Management

Permits Branch, Office of Air Management

100 North Senate Avenue, P.O. Box 6015

Indianapolis, Indiana 46206-6015

Any such application should be certified by the “authorized individual” as defined by 326

IAC 2-1.1-1.

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

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

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

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

required by law, and subject to the Permittee’s right under all applicable laws and regulations to
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assert that the information collected by the agency is confidential and entitled to be treated as such,

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

following:

(a) Enter upon the Permittee's premises where a 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.

[326 IAC 2-7-6(6)]

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

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

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

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

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

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

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

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

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

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

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

revoked for any of the following causes:

(a) Violation of any conditions of this permit.

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

(c) Changes in regulatory requirements that mandate either a temporary or permanent reduction of discharge of contaminants. However, the amendment of appropriate sections of this

permit shall not require revocation of this permit.

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

emissions during an air pollution episode.

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

permit is not consistent with purposes of this article.
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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

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

(a) Compliance testing on new emissions units shall be conducted within 60 days after achieving maximum production rate, but no later than180 days after initial start-up, if specified in

Section D of this approval. All testing shall be performed according to the provisions of 326

IAC 3-6 (Source Sampling Procedures), except as provided elsewhere in this permit,

utilizing any applicable procedures and analysis methods specified in 40 CFR 51, 40 CFR

60, 40 CFR 61, 40 CFR 63, 40 CFR 75, or other procedures approved by IDEM, OAM.

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

Indiana Department of Environmental Management

Compliance Data Section, Office of Air Management

100 North Senate Avenue, P. O. Box 6015

Indianapolis, Indiana 46206-6015

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

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

prior to the test date.

(b) All test reports must be received by IDEM, OAM, within forty-five (45) days after the completion of the testing. An extension may be granted by the IDEM, OAM, if the source submits

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

initial forty-five (45) day period.

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

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

Compliance Monitoring Requirements

C.10 Compliance Monitoring [326 IAC 2-1.1-11]

Compliance with applicable requirements shall be documented as required by this permit. The

Permittee shall be responsible for installing any necessary equipment and initiating any required

monitoring related to that equipment. All monitoring and record keeping requirements not already
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legally required shall be implemented when operation begins.

C.11 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.12 Compliance Monitoring Plan - Failure to Take Response Steps [326 IAC 1-6]

(a) The Permittee is required to implement a compliance monitoring plan to ensure that reasonable information is available to evaluate its continuous compliance with applicable requirements. This compliance monitoring plan is comprised of:

(1) This condition;

(2) The Compliance Determination Requirements in Section D of this permit; 

(3) The Compliance Monitoring Requirements in Section D of this permit; 

(4) The Record Keeping and Reporting Requirements in Section C (Monitoring Data

Availability, General Record Keeping Requirements, and General Reporting

Requirements) and in Section D of this permit; and

(5) A Compliance Response Plan (CRP) for each compliance monitoring condition of

this permit. CRP’s shall be submitted to IDEM, OAM upon request and shall be

subject to review and approval by IDEM, OAM. The CRP shall be prepared within

ninety (90) days after issuance of this permit by the Permittee and maintained on

site, and is comprised of:

(A) Response steps that will be implemented in the event that compliance

related information indicates that a response step is needed pursuant to

the requirements of Section D of this permit; and

(B) A time schedule for taking such response steps including a schedule for

devising additional response steps for situations that may not have been

predicted.

(b) For each compliance monitoring condition of this permit, appropriate response steps shall

be taken when indicated by the provisions of that compliance monitoring condition. Failure

to perform the actions detailed in the compliance monitoring conditions or failure to take the

response steps within the time prescribed in the Compliance Response Plan, shall constitute a violation of the permit unless taking the response steps set forth in the Compliance

Response Plan would be unreasonable.

(c) After investigating the reason for the excursion, the Permittee is excused from taking further

response steps for any of the following reasons:

(1) The monitoring equipment malfunctioned, giving a false reading. This shall be an

excuse from taking further response steps providing that prompt action was taken

to correct the monitoring equipment.

(2) The Permittee has determined that the compliance monitoring parameters established in the permit conditions are technically inappropriate, has previously submitted a request for an administrative amendment to the permit, and such request has
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not been denied or;

(3) An automatic measurement was taken when the process was not operating; or

(4) The process has already returned to operating within “normal” parameters and no

response steps are required.

(d) Records shall be kept of all instances in which the compliance related information was not

met and of all response steps taken.

C.13 Actions Related to Noncompliance Demonstrated by a Stack Test

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

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

shall take appropriate corrective actions. The Permittee shall submit a description of these

corrective actions to IDEM, OAM, within thirty (30) days of receipt of the test results. The

Permittee shall take appropriate action to minimize emissions from the affected emissions

unit while the corrective actions are being implemented. IDEM, OAM shall notify the

Permittee within thirty (30) days, if the corrective actions taken are deficient. The Permittee

shall submit a description of additional corrective actions taken to IDEM, OAM within thirty

(30) days of receipt of the notice of deficiency. IDEM, OAM reserves the authority to use

enforcement activities to resolve noncompliant stack tests.

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

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

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

extend the retesting deadline. Failure of the second test to demonstrate compliance with

the appropriate permit conditions may be grounds for immediate revocation of the permit

to operate the affected emissions unit.

The documents submitted pursuant to this condition do not require the certification by the “authorized individual” as defined by 326 IAC 2-1.1-1.

Record Keeping and Reporting Requirements

C.14 Malfunctions Report [326 IAC 1-6-2]

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

(a) A record of all malfunctions, including startups or shutdowns of any facility or emission control equipment, which result in violations of applicable air pollution control regulations or

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

shall be made available to the Indiana Department of Environmental Management (IDEM),

Office of Air Management (OAM) or appointed representative upon request.

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

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

Forms (2 pages). Notification shall be made by telephone or facsimile, as soon as practicable, but in no event later than four (4) daytime business hours after the beginning of said

occurrence.

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

of 326 IAC 1-6, and any other applicable rules. Information of the scope and expected duration of the malfunction shall be provided, including the items specified in 326 IAC 1-6-2(a)

(1) through (6).
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(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.15 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 C- Performance Testing, all observations, sampling, maintenance procedures, and record keeping,

required as a condition of this permit shall be performed at all times the equipment is

operating at normal representative conditions.

(b) As an alternative to the observations, sampling, maintenance procedures, and record keeping of subsection (a) above, when the equipment listed in Section D of this permit is not

operating, the Permittee shall either record the fact that the equipment is shut down or

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

would otherwise be required by this permit.

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

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

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

maintenance procedures, or record keeping, reasons for this must be recorded.

(e) At its discretion, IDEM may excuse such failure providing adequate justification is documented and such failures do not exceed five percent (5%) of the operating time in any

quarter.

(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.16 General Record Keeping Requirements [326 IAC 2-6.1-2]

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

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

or application. These records shall be kept at the source location for a minimum of three

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

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

request. If the Commissioner makes a written request for records to the Permittee, the

Permittee shall furnish the records to the Commissioner within a reasonable time.

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

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

(2) The dates analyses were performed;

(3) The company or entity performing the analyses;

(4) The analytic techniques or methods used;

(5) The results of such analyses; and 

(6) The operating conditions existing at the time of sampling or measurement.
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(c) Support information shall include, where applicable:

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

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

(3) All calibration and maintenance records;

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

to implement the Preventive Maintenance Plan did not cause or contribute to a

violation of any limitation on emissions or potential to emit. To be relied upon subsequent to any such violation, these records may include, but are not limited to:

work orders, parts inventories, and operator’s standard operating procedures.

Records of response steps taken shall indicate whether the response steps were

performed in accordance with the Compliance Response Plan required by Section

C - Compliance Monitoring Plan - Failure to take Response Steps, of this permit,

and whether a deviation from a permit condition was reported. All records shall

briefly describe what maintenance and response steps were taken and indicate

who performed the tasks.

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

operation begins.

C.17 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).

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

of this permit shall be submitted to:

Indiana Department of Environmental Management

Compliance Data Section, Office of Air Management

100 North Senate Avenue, P. O. Box 6015

Indianapolis, Indiana 46206-6015

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

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

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

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

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

(d) Unless otherwise specified in this permit, any 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:
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(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 this permit becomes a Minor

Source Operating Permit and ending on the last day of the reporting period.

C.18 Annual Notification [326 IAC 2-6.1-5(a)(5)]

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

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

in this permit.

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

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

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

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

must be signed by an authorized individual.

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

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

year to:

Compliance Data Section, Office of Air Management

Indiana Department of Environmental Management

100 North Senate Avenue, P.O. Box 6015

Indianapolis, IN 46206-6015

(d) The notification shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the

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

timely if received by IDEM, OAM, on or before the date it is due.
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SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS

Emissions Unit Description:

(a) One (1) chrome plating tank, identified as Tank 1, controlled with a composite mesh pad system,

and exhausting to stack S/V 1, maximum cumulative rectifier capacity: 29,400,000 ampere hours

per year.

(b) One (1) chrome plating tank, identified as Tank 2, controlled with a composite mesh pad system,

and exhausting to stack S/V 1, maximum cumulative rectifier capacity: 11,760,000 ampere hours

per year.

(c) One (1) space heater, identified as H1, fired by natural gas, heat input capacity: 0.125 million

British thermal units per hour.

(d) One (1) space heater, identified as H2, fired by natural gas, heat input capacity: 0.1 million British

thermal units per hour.

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

information and does not constitute enforceable conditions.)

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 and 2. A copy of this rule is

attached. The Permittee shall comply with the requirements of this condition on and after the

compliance date for the tanks.

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

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

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

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

(b) The hard chromium electroplating tanks, identified as Tank 1 and Tank 2, above, are considered a small, new hard chromium electroplating operation. During tank operation, the

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

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

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

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

The following work practice standards apply to Tanks 1 and 2:
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(a) At all times, including periods of startup, shutdown, malfunction and excess emissions, the

Permittee shall operate and maintain Tanks 1 and 2, including 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, OAM, which may include, but is not

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

of the source.

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

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

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

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

(2) Fails to provide for the operation of Tanks 1 and 2, 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, composite mesh pad system, monitoring equipment or other causes of

excess emissions as quickly as practicable.

For Tanks 1 and 2, the Permittee shall comply with the requirements of this condition on and after

the start-up date of each tank.

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

malfunctions and periods of excess emissions.

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

A Preventive Maintenance Plan (PMP), in accordance with Condition C.2 - Preventive Maintenance

Plan, of this permit, is required for the Tanks 1 and 2 and the composite mesh pad system.

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

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

no later than the startup date of Tanks 1 and 2. The OMP shall specify the operation and

maintenance criteria for the tanks, the composite mesh pad system and monitoring equipment and shall include the following elements:

For the composite mesh-pad system (CMP):

(1) 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.
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(2) Quarterly visual inspection of the back portion of the mesh pad closest to the fan

to ensure there is no breakthrough of chromic acid mist.

(3) Quarterly visual inspection of the duct work from the tank to the control device to

ensure there are no leaks.

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

recommendations.

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

the monitoring equipment, during similar malfunction or period of excess emissions events,

and a program for corrective action for such events.

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

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

record the actions taken for that event and shall report by phone such actions within two (2)

working days after commencing actions inconsistent with the plan. This report shall be

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

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

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

upon request, by IDEM, OAM for the life of Tanks 1 and 2 or until the tank is no longer subject

to the provisions of 40 CFR 63.340. In addition, if the OMP is revised, the Permittee shall

keep previous versions of the OMPs on record to be made available for inspection, upon

request by IDEM, OAM for a period of five (5) years after each revision to the plan.

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)(1)] [40 CFR 63.343(b)(2)] [40 CFR 63.7]

[40 CFR 63.344]

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

of Tanks 1 and 2 using the procedures and methods in 40 CFR 63.344 and 40 CFR 63.7

and in accordance with Section C - Performance Testing.

(b) The Permittee is not required to further test Tanks 1 and 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 limits specified in Condition D.1.3 shall

be determined by a performance test conducted in accordance with 40 CFR 63.344 and

Section C - Performance Testing.

(c) Any change, modification, or reconstruction of Tanks 1 and 2, the composite mesh pad

system or monitoring equipment may require additional performance testing conducted in

accordance with 40 CFR 63.344 and Section C - Performance Testing.
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D.1.8 Establishing Site-Specific Operating Parameter Values [40 CFR 63.343(c)] [40 CFR 63.344(d)]

During the initial performance test and pursuant to 40 CFR 63.343(c)(1)(i), when using a composite

mesh-pad system to comply with the limits specified in Condition D.1.3, the Permittee shall

determine the outlet chromium concentration using the test methods in 40 CFR 63.344(c) and shall

establish as a site-specific operating parameter the pressure drop across the system, setting the

value that corresponds to compliance with the applicable emission limitation using the procedures

in 40 CFR 63.344(d)(4) and (5). The Permittee may conduct multiple performance tests to establish

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

drop measured over the three test runs of one performance test, and accept ±1 inch of water

column from this value as the compliant range.

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

D.1.9 Monitoring to Demonstrate Continuous Compliance [326 IAC 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2)]

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

with the limits specified in Condition D.1.3, the Permittee shall monitor and record the pressure drop across the composite mesh-pad system during tank operation once each day that

the hard chromium electroplating tank is operating. To be in compliance with the standards,

the composite mesh-pad system shall be operated within ±1 inch of water column of the

pressure drop value established during the initial performance test, or within the range of

compliant values for pressure drop established during multiple performance tests.

(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.

Record Keeping and Reporting Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 2-6.1-5(a)(2)]

D.1.10 Record Keeping Requirements [326 IAC 2-5.1-3(e)(2)] [40 CFR 63.346]

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

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

with Section C - General Record Keeping Requirements of this permit and include a minimum of

the following:

(a) Inspection records for the 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 1 and 2, the composite mesh pad system

and monitoring equipment.
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(c) Records of the occurrence, duration, and cause (if known) of each malfunction of Tanks 1

and 2, the 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 1 and 2, the 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.1.9(b), of each tank, during the

reporting period.

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

tank expended during each month of the reporting period, and the total capacity expended

to date for a reporting period.

(l) All documentation supporting the notifications and reports required by 40 CFR 63.9 and

63.10 (Subpart A, General Provisions) and by Condition D.1.11.

D.1.11 Reporting Requirements [326 IAC 2-5.1-3(e)(2)] [326 IAC 3-6-4(b)] [40 CFR 63.344(a), 63.345 and

63.347]

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

address specified in Section C - General Reporting Requirements.

(a) Notifications:

(1) Initial Notifications

The Permittee shall submit an Initial Notification for each new or reconstructed tank

as follows:

(A) A notification of the actual dates when construction of Tanks 1 and 2 commenced shall be submitted no later than thirty (30) days after such dates.

(B) A notification of the actual date of startup of Tanks 1 and 2 shall be submitted within thirty (30) days after such date.

(2) Notification of Performance Test

The Permittee shall notify IDEM, OAM in writing of their intention to conduct a

performance test at least sixty (60) days before the test is scheduled to begin.

(A) Pursuant to Section C - Performance Testing, a test protocol shall be sub-
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mitted no later than thirty-five (35) days prior to the intended test date.

(B) In the event the Permittee is unable to conduct the performance test as

scheduled, pursuant to 40 CFR 63.7(b)(2) the Permittee shall notify IDEM,

OAM within five (5) days prior to the scheduled performance test date and

specify the date when the performance test is rescheduled. Pursuant to

Section C - Performance Testing, the rescheduled performance test date

shall be no sooner than fourteen (14) days after IDEM, OAM is notified in

writing of the need to reschedule.

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

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

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

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

(B) The NCS for Tanks 1 and 2 shall be submitted to IDEM, OAM no later than

forty-five (45) days following completion of the compliance demonstration

pursuant to Section C - Performance Testing.

(4) Notification of Construction or Reconstruction

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

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

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

(NCR) to IDEM, OAM. In addition, the Permittee may not change, modify, or

reconstruct Tanks 1 and 2 without submitting a Notification of Construction or

Reconstruction (NCR) to IDEM, OAM.

(A) The NCR shall contain the information identified in 40 CFR 63.345(b) (2)

and (3).

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

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

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

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

control technique or device [i.e., the addition of duct work to the CMP

system].

(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 and 2 serves as this notification.

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

OAM before construction, modification, or reconstruction may commence.
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(b) Performance Test Results

The Permittee shall document results from the initial performance test and any future performance tests in a complete test report that contains the information required in 40 CFR

344(a).

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

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

following the completion of the performance test.

(c) Ongoing Compliance Status Report

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

of Tanks 1 and 2 using the Ongoing Compliance Status Report form provided with this

permit. This report shall contain the information specified in 40 CFR 63.347(g)(3).

Because Tanks 1 and 2 are located at site that is an area source of hazardous air pollutants

(HAPs), the Ongoing Compliance Status Report shall be retained on site and made

available to IDEM, OAM upon request.

(1) The Ongoing Compliance Status Report shall be completed according to the following schedule except as provided in paragraphs (c)(2).

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

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

begin operation.

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

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

December 31.

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

and submitted to IDEM, OAM:

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

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

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

D.1.9(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.1.9(b).

Once the Permittee reports an exceedance as defined above, Ongoing Compliance

Status Reports shall be submitted semiannually until a request to reduce reporting

frequency in accordance with 40 CFR 63.347(g)(2) is approved.

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

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

submitted instead of being retained on site, if these measures are necessary to

accurately assess the compliance status of the source.
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INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR MANAGEMENT

COMPLIANCE DATA SECTION

MINOR SOURCE OPERATING PERMIT

CHROMIUM ELECTROPLATING AND ANODIZING NESHAP

ONGOING COMPLIANCE STATUS REPORT

Source Name: Roembke Manufacturing and Design

Source Address: 1580 Baker Drive, Ossian, Indiana 46777

Mailing Address: 1580 Baker Drive, Ossian, Indiana 46777

MSOP No.: 179-11704-00027

Tank ID #:

Type of process: Hard Chromium Electroplating

Monitoring Parameter: Pressure drop across the composite mesh pad system

Parameter Value:

Limits: Total chromium in the exhaust gas stream discharged to the atmosphere shall

not exceed 0.015 mg/dscm [6.6x10-6 gr/dscf]

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

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

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

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

and retain on site unless otherwise notified.

This form consists of 2 pages Page 1 of 2

BEGINNING AND ENDING DATES OF THE REPORTING PERIOD:

TOTAL OPERATING TIME OF THE TANK DURING THE REPORTING PERIOD:

MAJOR AND AREA SOURCES: CHECK ONE

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

RANGE OF VALUES OCCURRED DURING THIS REPORTING PERIOD.

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

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

RESULT IN MORE FREQUENT REPORTING).

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

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

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

JAN APR JUL OCT

FEB MAY AUG NOV

MAR JUN SEP DEC

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

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

JAN APR JUL OCT

FEB MAY AUG NOV

MAR JUN SEP DEC
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CHROMIUM ELECTROPLATING AND ANODIZING NESHAP

ONGOING COMPLIANCE STATUS REPORT

ATTACH A SEPARATE PAGE IF NEEDED Page 2 of 2

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

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

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

REPORT:

ADDITIONAL COMMENTS:

ALL SOURCES: CHECK ONE

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

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

ACCURATE AND TRUE TO THE BEST OF MY KNOWLEDGE.

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

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

Submitted by: 

Title/Position:

Signature:

Date:

Phone: 

Attach a signed certification to complete this report.

MALFUNCTION REPORT

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
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OFFICE OF AIR MANAGEMENT

FAX NUMBER - 317 233-5967

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

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

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

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

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

?_____, 25 TONS/YEAR REDUCED SULFUR COMPOUNDS ?_____, 25 TONS/YEAR FLUORIDES ?_____, 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: Roembke Manufacturing and Design PHONE NO. : 219 - 622 - 4135

LOCATION: (CITY AND COUNTY) Ossian / Wells

PERMIT NO. 179-11704 AFS PLANT ID: 179-00027 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

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

applicable to Rule 326 IAC 1-6 and to qualify for
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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
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR MANAGEMENT

COMPLIANCE DATA SECTION

MINOR SOURCE OPERATING PERMIT

ANNUAL NOTIFICATION

This form should be used to comply with the notification requirements under 326 IAC 2-6.1-5(a)(5).

Company Name: Roembke Manufacturing and Design

Address: 1580 Baker Drive

City: Ossian

Phone #: (219) 622-4135

MSOP #: 179-11704-00027

I hereby certify that Roembke Manufacturing and Design is 9 still in operation.

9 no longer in operation.

I hereby certify that Roembke Manufacturing and Design is 9 in compliance with the requirements

of MSOP 179-11704-00027.

9 not in compliance with the

requirements of MSOP 179-11704-

00027.

Authorized Individual (typed):

Title:

Signature:

Date:

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

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

achieved.

Noncompliance:
Page 1 of 4

Indiana Department of Environmental Management

Office of Air Management

Addendum to the

Technical Support Document for New Construction and Operation

Source Name: Roembke Manufacturing and Design

Source Location: 1580 Baker Drive, Ossian, Indiana 46777

County: Wells

Construction Permit No.: MSOP 179-11704-00027

SIC Code: 3470

Permit Reviewer: CarrieAnn Ortolani

On April 24, 2000, the Office of Air Management (OAM) had a notice published in the Bluffton News

Banner, Bluffton, Indiana, stating that Roembke Manufacturing and Design had applied for a construction

permit to construct and operate stationary small, hard chromium electroplating source with composite mesh

pad systems as controls. The notice also stated that OAM proposed to issue a permit for this installation and

provided information on how the public could review the proposed 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.

On May 8, 2000, Evelyn B. Crooks of Environmental Compliance Source, Ltd., submitted comments

on the proposed construction permit. The summary of the comments and corresponding responses are as

follows: The permit language, if changed, has deleted language as strikeouts and new language bolded.

Comment 1:

Condition A.1 - The authorized individual is Martin F. Adam, Jr. Mr. Adam signed the permit application.

Response 1:

Section A.1 has been revised as follows:

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

The Permittee owns and operates stationary small, hard chromium electroplating source.

Authorized Individual: Jim Steffen Martin F. Adam, Jr.

Source Address: 1580 Baker Drive, Ossian, Indiana 46777

Mailing Address: 1580 Baker Drive, Ossian, Indiana 46777

Phone Number: 219 - 622 - 4135

SIC Code: 3470

County Location: Wells

County Status: Attainment for all criteria pollutants

Source Status: Minor Source Operating Permit

Minor Source, under PSD Rules;

Minor Source, Section 112 of the Clean Air Act

Comment 2:

Condition C.16(d) - Roembke interprets this condition as taking effect when the tank operations begin,

not on the date of permit issuance.
Roembke Manufacturing and Design Page 2 of 4

Ossian, Indiana MSOP 179-11704-00027

Permit Reviewer:MES

Response 2:

As indicated in Condition C.16(d), all record keeping requirements not already legally required shall

be implemented when operation begins.

Comment 3:

Condition C.17 - This condition contradicts Condition D.1.11(c)(1) and the TSD. Roembke is required

to complete an annual Ongoing Compliance Status Report (OCSR) unless excess emissions or

malfunctions exceed the time limits in D.1.11(c)(2).

Roembke requests confirmation that this report replaces the OCSR previously filed under the

NESHAP rule. If this report does not replace the earlier one, Roembke will not accept a duplicate

requirement as a permit condition.

Response 3:

The Semi-annual Compliance Monitoring Report is a separate report from the Ongoing Compliance

Status Report. The Semi-annual Compliance Monitoring Report is used to affirm that the source

has met all of the compliance monitoring requirements by reporting any deviation from the

requirements and the date(s) of each deviation. This is report is submitted to IDEM semi-annually.

The Ongoing Compliance Status Report documents the ongoing compliance status of Tanks 1 and

2 using the Ongoing Compliance Status Report form provided with the permit. The Ongoing

Compliance Status Report is only submitted to IDEM, OAM, when 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.1.9(b) for the reporting period; or 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.1.9(b). Once the Permittee reports an exceedance as defined above,

Ongoing Compliance Status Reports shall be submitted semi-annually until a request to reduce

reporting frequency in accordance with 40 CFR 63.347(g)(2) is approved. Otherwise, the Ongoing

Compliance Status Report is kept on site and made available to IDEM upon request. The Ongoing

Compliance Status Reports may contain some information from the Semi-annual Compliance

Monitoring Report.

Comment 4:

Condition C.17(g) - Roembke interprets this condition as the first report period commencing on the

date when tank operations begin, not the date of permit issuance. This is a construction permit as

well as an MSOP.

Response 4:

This conditions will become effective when the permit becomes a Minor Source Operating Permit as

described by Condition B.6. Condition C.17(g) has been revised as follows:

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

becomes a Minor Source Operating Permit and ending on the last day of the reporting

period.

Comment 5:

Condition D.1.5 - The Preventive Maintenance Plan requirement is in Section C.2, not Section B.
Roembke Manufacturing and Design Page 3 of 4

Ossian, Indiana MSOP 179-11704-00027

Permit Reviewer:MES

Response 5:

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

A Preventive Maintenance Plan (PMP), in accordance with Section B Condition C.2 - Preventive

Maintenance Plan, of this permit, is required for the Tanks 1 and 2 and the composite mesh pad

system.

Comment 6:

Condition D.1.11(a)(1) - Roembke requests clarification of the Initial Notifications. Is this in addition

to or instead of the Affidavit of Construction? If it is an additional notification, Roembke objects to the

burden of unnecessary and redundant reports.

Response 6:

The Initial Notifications in Condition D.1.11(a)(1) are required by 40 CFR 63.344(a), 63.345 and

63.347. The Affidavit of Construction is required by 326 IAC 2-5.1-3(h). Pursuant to 326 IAC 2-5.1-

3(i)(1), a source may operate upon submission of an affidavit of construction that affirms that the

source is described by, and will comply with, the construction permit as issued or previously

amended. Therefore, there are no changes to the permit as a result of this comment.

Comment 7:

Condition D.1.11(a)(3) - What is the format for the NCS report: How does it differ from the performance test results required in Condition C.9?

Response 7:

There is no set format for the NCS provided it lists, for each tank, the information identified in 40 CFR

63.347(e)(2). As indicated in Condition C.9, Condition D.1.11(a)(3) and Condition D.1.11(b), all test

reports must be received by IDEM, OAM, within forty-five (45) days after the completion of the testing.

The test report required by Condition C.9 is the same as that required by Conditions D.1.11(a)(3) and

D.1.11(b). Therefore, the Permittee can comply with all three (3) conditions by submitting one report,

with testing for each tank.

Comment 8:

Condition D.1.11(a)(4) - Roembke requests that equivalent language to provide Operational Flexibility

[as defined in 326 IAC 2-8-15(b) through (d)] be added. This flexibility is as important (if not more so)

to a minor source permit holder as it is to a FESOP permit holder.

Response 8:

The operational flexibility given to sources with Federally Enforceable State Operating Permits

(FESOPs) by 326 IAC 2-8-15(b) and (c) only apply to FESOP sources because of the source-wide

emission limitations in the FESOP. Since there are no emission limitations in this permit and this is

not a FESOP, these rules cannot be applicable. There were no alternate operating scenarios

indicated in the permit application and this is not a FESOP source. Therefore, 326 IAC 2-8-15(d) also

cannot be applicable.

Comment 9:

Condition D.1.11(b) - Please see the related comment at D.1.11(a)(3). Roembke requests clarification regarding those items (in addition to the performance test results) that are required in the NCS.
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Ossian, Indiana MSOP 179-11704-00027

Permit Reviewer:MES

Response 9:

See Response 7.

Comment 10:

Condition D.1.11(c)(1) - Please see the related comment to Condition C.17 above.

Response 10:

See Response 3.

Comment 11:

General Comment - The reporting and documentation requirements of this permit are a major burden

totally out of proportion with the source's potential to emit.

Response 11:

All Conditions in the permit are necessary for the source to comply with the requirements of 326 IAC

2-5.1-3, Permits, and 326 IAC 2-6.1, Minor Source Operating Permit. Nearly all of the requirements

are independently required by 40 CFR 63, Subpart N - National Emission Standards for Chromium

Emissions From Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks.

The high toxicity of this regulated pollutant results in significant health impacts in the many

communities of Indiana located near sources of chromium mist. IDEM is unaware of any

information that contradicts studies released by U.S. EPA that link exposure to chromium in the

ambient air with cancer. IDEM believes there is valid justification for requiring these sources of

airborne hexavalent chromium to obtain a Minor Source Operating Permit (MSOP). IDEM’s MSOP

requirement for chrome sources provides a simpler and cheaper permit process than the Title V

permitting process.

To sustain the effectiveness of Indiana’s compliance assistance program for chromium emissions

is IDEM’s goal. A single reference document readily available to all interested parties that explains

all major site-specific requirements should minimize future confusion. It will help to ensure that

noncompliance is minimized.

Upon further review, the OAM has decided to make the following change to the construction permit:

The permit language is changed to read as follows (deleted language appears as strikeouts, new language

is bolded):

Condition D.1.9(b) is revised as follows:

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

is turned on. If the amount of time that no part is in the tank is fifteen minutes or longer, that time

is not considered operating time. Likewise, if the amount of time between placing parts in the tank

(i.e., when no part is in the tank) is less that than fifteen minutes, that time between plating the two

parts is considered operating time.
Page 1 of 7

Indiana Department of Environmental Management

Office of Air Management

Technical Support Document (TSD) for a

New Source Construction and Minor Source Operating Permit

Source Background and Description

Source Name: Roembke Manufacturing and Design

Source Location: 1580 Baker Drive, Ossian, Indiana 46777

County: Wells

SIC Code: 3470

Operation Permit No.: MSOP 179-11704-00027

Permit Reviewer: CarrieAnn Ortolani

The Office of Air Management (OAM) has reviewed an application from Roembke Manufacturing

and Design relating to the construction and operation of a small, hard chromium electroplating

source.

Permitted Emission Units and Pollution Control Equipment

There are no permitted emission units at this source.

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

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

(a) One (1) chrome plating tank, identified as Tank 1, controlled with a composite mesh pad

system, and exhausting to stack S/V 1, maximum cumulative rectifier capacity: 29,400,000

ampere hours per year.

(b) One (1) chrome plating tank, identified as Tank 2, controlled with a composite mesh pad

system, and exhausting to stack S/V 1, maximum cumulative rectifier capacity: 11,760,000

ampere hours per year.

(c) One (1) space heater, identified as H1, fired by natural gas, heat input capacity: 0.125

million British thermal units per hour.

(d) One (1) space heater, identified as H2, fired by natural gas, heat input capacity: 0.1 million

British thermal units per hour.
Roembke Manufacturing and Design Page 2 of 7

Ossian, Indiana MSOP 179-11704-00027

Permit Reviewer:MES

Existing Approvals

There are no existing approvals for this source.

Stack Summary

Stack ID Operation Height

(feet)

Diameter

(feet)

Flow Rate

(acfm)

Temperature

(EF)

S/V 1 Chrome Plating Tanks

1 and 2

20.0 1.17 N/A 68

Enforcement Issue

There are no enforcement actions pending.

Recommendation

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

is based on the following facts and conditions:

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

additional information submitted by the applicant.

A complete application for the purposes of this review was received on December 28, 1999. A letter

was received on March 27, 2000 indicating that the source is moving to the location in this permit.

Therefore, the source is being permitted as a new minor source.

Emission Calculations

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

less than ten (10) tons per year and Roembke Manufacturing and Design 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. See

Appendix A (pages 1 and 2 of 2) of this document for detailed emissions calculations for natural gas

combustion.

Potential To Emit

Pursuant to 326 IAC 2-1.1-1(16), Potential to Emit is defined as “the maximum capacity of a stationary source or emissions unit to emit any air pollutant under its physical and operational design. Any

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

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

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

by the U. S. EPA, the department, or the appropriate local air pollution control agency.”

Pollutant Potential To Emit

(tons/year)

PM 0.002

PM10 0.007

SO2 0.001
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Ossian, Indiana MSOP 179-11704-00027

Permit Reviewer:MES

Pollutant Potential To Emit

(tons/year)

VOC 0.005

CO 0.083

NOX 0.099

HAPs Potential To Emit

(tons/year)

Chromium less than 10

TOTAL less than 25

(a) The potential to emit (as defined in 326 IAC 2-7-1(29)) of each pollutant is less than 100

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

Registration, because the source 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). Therefore, the source is subject to the provisions of 326 IAC 2-5.1-3(a)(2)

(A) and 326 IAC 2-6.1-3(a).

Actual Emissions

No previous emission data has been received from the source.

Limited Potential to Emit

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

units.

Limited Potential to Emit

(tons/year)

Process/facility PM PM10 SO2 VOC CO NOX HAPs

Chromium

Electroplating

0.00 0.00 0.00 0.00 0.00 0.00 < 10

Space Heating 0.002 0.007 0.001 0.005 0.083 0.099 0.002

Total

Emissions

0.002 0.007 0.001 0.005 0.083 0.099 < 10
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Ossian, Indiana MSOP 179-11704-00027

Permit Reviewer:MES

County Attainment Status

The source is located in Wells County.

Pollutant Status

PM10 attainment

SO2 attainment

NO2 attainment

Ozone attainment

CO attainment

Lead attainment

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

of ozone. Therefore, VOC and NOX emissions are considered when evaluating the rule

applicability relating to the ozone standards. Wells County has been designated as attainment for ozone. Therefore, VOC and NOX

 emissions were reviewed pursuant to the

requirements for PSD, 326 IAC 2-2 and 40 CFR 52.21.

(b) Wells County has been classified as attainment or unclassifiable for all other 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.

(c) 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 Emissions

(ton/yr)

PM 0.002

PM10 0.007

SO2 0.001

VOC 0.005

CO 0.083

NOX 0.099
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Ossian, Indiana MSOP 179-11704-00027

Permit Reviewer:MES

(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.

Part 70 Permit Determination

326 IAC 2-7 (Part 70 Permit Program)

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

(PTE) of:

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

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

(c) any combination of HAPS is less than twenty-five (25) tons/year.

This is the first air approval issued to this source.

Federal Rule Applicability

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

60) applicable to this source.

(b) Tanks 1 and 2 are subject to the National Emission Standards for Hazardous Air Pollutants,

326 IAC 14, (40 CFR 63, Subpart N, and 326 IAC 20-1-1). A copy of this rule is attached.

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

operations are subject to the following conditions:

(1) Emission limitation:

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

compliance date for the tanks.

The hard chromium electroplating tanks, identified as Tanks 1 and 2, are considered a small, new hard chromium electroplating operation. During tank operation, the

Permittee shall control chromium emissions discharged to the atmosphere from the

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

discharged to the atmosphere to exceed fifteen-thousandth milligrams of total

chromium per dry standard cubic meter of ventilation air (0.015 mg/dscm) [equivalent to six and six-tenths times ten raised to the power of negative six grains of total

chromium per dry standard cubic foot of ventilation air (6.6x10-6 gr/dscf)].

(2) Monitoring Requirements:

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

comply with the limits specified above, 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.
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Ossian, Indiana MSOP 179-11704-00027

Permit Reviewer:MES

(3) Reporting Requirements:

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

of the chromium electroplating operation. This report shall be completed annually,

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

exceedance of chromium air emission limits (as defined in 40 CFR Part 63.347

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

Indiana Department of Environmental Management

Air Compliance Branch, Office of Air Management

Chromium Electroplating

100 North Senate Avenue, P.O. Box 6015

Indianapolis, Indiana 46206

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

reporting requirement as indicated in the chromium electroplating NESHAP.

State Rule Applicability - Entire Source

326 IAC 2-6 (Emission Reporting)

This source is located in Wells County and the potential to emit VOC and NOX is less than one

hundred (100) 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 forty percent (40%) 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.

State Rule Applicability - Individual Facilities

There are no state rules applicable to individual facilities at this source. 

Air Toxic Emissions

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

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

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

as air toxics on the Office of Air Management (OAM) Construction Permit Application Form Y.

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

to Section 112 of the 1990 Clean Air Act Amendments.
Roembke Manufacturing and Design Page 7 of 7

Ossian, Indiana MSOP 179-11704-00027

Permit Reviewer:MES

Conclusion

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

attached proposed Minor Source Operating Permit 039-11719-00413.
Appendix A: Emissions Calculations Page 1 of 2 TSD App A

Natural Gas Combustion Only

 MM BTU/HR <100

Two (2) Space Heaters

Company Name: Roembke Manufacturing and Design

Address City IN Zip: 1580 Baker Drive, Ossian, Indiana 46777

MSOP: 179-11704

Plt ID: 179-00027

Reviewer: CarrieAnn Ortolani

Date: February 23, 2000

Heat Input Capacity Potential Throughput

MMBtu/hr MMCF/yr

0.23 1.97

Pollutant

PM* PM10* SO2 NOx VOC CO

Emission Factor in lb/MMCF 1.9 7.6 0.6 100.0 5.5 84.0

**see below

Potential Emission in tons/yr 0.002 0.007 0.001 0.099 0.005 0.083

*PM emission factor is filterable PM only. PM10 emission factor is filterable and condensable PM10 combined.

**Emission Factors for NOx: Uncontrolled = 100, Low NOx Burner = 50, Low NOx Burners/Flue gas recirculation = 32

Methodology

All emission factors are based on normal firing.

MMBtu = 1,000,000 Btu

MMCF = 1,000,000 Cubic Feet of Gas

Potential Throughput (MMCF) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMCF/1,000 MMBtu

Emission Factors are from AP 42, Chapter 1.4, Tables 1.4-1, 1.4-2, 1.4-3, SCC #1-02-006-02, 1-01-006-02, 1-03-006-02, and 1-03-006-03

(SUPPLEMENT D 3/98)

Emission (tons/yr) = Throughput (MMCF/yr) x Emission Factor (lb/MMCF)/2,000 lb/ton

Note: Check the applicable rules and test methods for PM and PM10 when using the above emission factors to confirm that the

correct factor is used (i.e., condensable included/not included).

See page 2 for HAPs emissions calculations.
Appendix A: Emissions Calculations Page 2 of 2 TSD App A

Natural Gas Combustion Only

 MM BTU/HR <100

Two (2) Space Heaters

HAPs Emissions

Company Name: Roembke Manufacturing and Design

Address City IN Zip: 1580 Baker Drive, Ossian, Indiana 46777

MSOP: 179-11704

Plt ID: 179-00027

Reviewer: CarrieAnn Ortolani

Date: February 23, 2000

HAPs - Organics

Benzene Dichlorobenzene Formaldehyde Hexane Toluene

Emission Factor in lb/MMcf 2.1E-03 1.2E-03 7.5E-02 1.8E+00 3.4E-03

Potential Emission in tons/yr 2.070E-06 1.183E-06 7.391E-05 1.774E-03 3.351E-06

HAPs - Metals

Lead Cadmium Chromium Manganese Nickel

Emission Factor in lb/MMcf 5.0E-04 1.1E-03 1.4E-03 3.8E-04 2.1E-03

Potential Emission in tons/yr 4.928E-07 1.084E-06 1.380E-06 3.745E-07 2.070E-06

Methodology is the same as page 1.

The five highest organic and metal HAPs emission factors are provided above. 

Additional HAPs emission factors are available in AP-42, Chapter 1.4.