# State of IIlil10is 

# ENVIRONMENTAL PROTECTIONAGENCY
Mary A. 

### Cade, Director P

. O. Box 19506, Springfield,IL 62794

-9506 217/182-2113 OPERATING PERMIT FOR HARD CHROME ELECTRO?LATING OPERATION NESHAP SOURCE PERMITTEE Economy Plating. Inc

. 

### Attn : Victor J

. 

### Koerner 2350 Nor th Elston 

### Chicago, Illinois 60614 I.D. No.: 03160QCVM Application No.: 73031926 Apnlicant ' s Designation : Date Recei.ved : January 29 , 1998 Subject: C hrome Electroplating Date Issued : March 31 , 1998 Location: 2350 N orth Elston, Chicago Expiration Date : March 31, 2003**Pe~t** 

### is hereby granted to the above-designated PeDmittee to OPERATE emission unit(s) and/or air pollution control equipment consisting of c hrome plating tanks Ul and #4, each controlled by a single stage compo site mesh pad (CI>lP) system with mist eliminator, and hard chrome p lating tanks U5 and #6, both controlled by a 4-stage CHP system as described i n the above- referenced application

. This Permit is subject standard condition s attached hereto and the following special condition (s) : hard

lao Air pollution control equipment associated with a hard chrome electroplating tank(s) shall be operated at all times during the operation of the tank

. to

b

. Hard chrome electroplating tank(s) controlled by a common add

- on air pollution control device shall not e xceed the following limits :

Equipment Existing Hard Chrome Electroplating Tanks Chr omium Emissions !mg/dscml 0

. 03 This limit is the National Emissions Standard for Hard Chromium Electroplating Tanks, 40 CFR Part 63 Subpart N and is based on the actual annual cumulative rectifier capacity of the hard chrome electroplating tanks being less than 60 million amp-hrs/year. An electroplating tank(s) installed before December 16, 1993, is considered as existing tank(s). compliance with the limit shall be determined from initial performance testing and ongoing compliance monitoring requirements . as required by conditions in this permit.

c. Failure to oper ate in accordance with operating parameter value, determined during initial performance testing shall be considered a violation of the above limit, pursuant to 40 CrR 63 Subpart N

. d

. The Permittee shall be in compliance w i th 40 CFR 63 Subpart N - National Emission Standard for hard chrome**tan :(s)**  on or before January 25, 1997

. ;' IPage 2
2. The operation and maintenance practices required by 40 CFR 63.342(f) shall be implemented for control systems used on hard chrome plating tanks. The following operation and maintenance procedures for the composite mesh pad control systems; pursuant to 40 CFR 63.342(f) (3) (i) (B):
a. A quarterly visual inspection of composite mesh pad (CMP) system 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 devices. b. A 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. A quarterly visual inspection of duct work from the tank(s) to the control device to ensure there are no leaks. d. Perform wash-down of the composite mesh-pads in accordance with manufacturer's recommendations. 3a. The Permittee shall develop and implement an operation and maintenance (0 

### & M) plan for hard chrome plating tanks which shall include at least the following, pursuant to 40 CFR**6~.342(f)** (3): i. Description of the operation and maintenance criteria for the control devices and monitoring equipment in use. ii. A checklist to document the operation and maintenance of the equipment. iii. Required operation and maintenance procedures, pursuant to 40 CFR 63.342(f) (Condition 2). iv. Procedure to follow to ensure that equipment or process malfunctions due to poor maintenance or other preventable conditions do not occur.
v. Procedure for identifying malfunctions and for implementing corrective actions. b. The Permittee may use any Standard Operating Procedure (SOP) manuals, Occupational Safety and Health Administration (OSHA) plans or other existing plans as part of the operation and maintenance plan, as long as they meet all the criteria of Condition 3(a). 4. The Permittee shall maintain records required by 40 CFR 63.346(b) for all chrome electroplating tanks to demonstrate compliance, including the following:
a. Records of monitoring data required by 40 CFR 63.343(c). 

### i. Pressure drop across each CMP system, determined daily.\ ,

Page 3
b. Inspection records for the control device and monitoring equipment, to document that the inspection and maintenance required by the work practice standards of 40 CFR 63.342(f) have taken place. The record can take the form of a checklist and should identify the device inspected, the date of inspection, a brief description of the working condition of the device during the inspection, and any actions taken to correct deficiencies found during the inspection.
c. Records of all maintenance performed on the chrome plating tanks, as related to emissions, the associated control system and monitoring equipment. d. Records of the occurrence, duration, and cause (if known) of each malfunction of the chrome plating process, associated control system and monitoring equipment.
e. Records of actions taken during periods of malfunction when such actions are inconsistent with the operation and maintenance plan. f. Records, which may take the form of checklists, necessary to demonstrate consistency with the operation and maintenance plan required by 40 CFR 63.342(f) (3). g. Copies of test reports documenting results of all performance tests and all measurements as may be necessary to determine the conditions of performance tests, including measurements necessary to determine compliance with the special compliance procedures of 40 CFR 63.344(e). h. 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 is collected. i. The specific identification**(i.e~,** the date and time of commencement and completion) of each period of excess emissions, as indicated by monitoring data. Records of excess emissions that occurs during malfunction of the process, control, or monitoring equipment. j. The specific identification (i.e., the date and time of commencement and completion) of each period of excess emissions, as indicated by monitoring data. Records of excess emissions that occurs during periods other than malfunction of the subject chrome plating tanks and associated control devices. k. Records for the total process operating time of the affected chrome plating tank(s) during the reporting period. 1. Copies of the notifications and reports required by 40 CFR Part 63.9, 63.10, and 63.347 with supporting documentation.Page 4

m. Records demonstrating the maximum cumulative rectifier capacity, if hard chrome plating is less than 60 million amp-hrs per year, or of the actual cumulative rectifier capacity of hard chromium electroplating tank(s) at a facility expended during each month and the total capacity expended during each reporting period.

n. All records shall be retained for a period of five years, pursuant to 40 eFR 63.10(b) (1). 5. The Permittee shall comply with the compliance reporting requirements of 40 eFR 63.347 including the following: A notification of compliance status, signed by the responsible official who shall certify its accuracy" attesting to whether the affected source has complied with Subpart N, pursuant to 40 eFR 63.347(e). The notification shall be submitted within 90 days of, the completion of the compliance demonstration required by 40 eFR 63.343(b) and construction permit 97040058. The notification shall list the following:
a. The applicable emission limitation and the methods that were used to determine compliance with this limitation. b. The performance test report documenting the results of the performance test, which contains the elements required by 40 eFR 63.344(a), including measurements and calculations to support the special compliance provisions of 40 eFR 63.344(e) if these are being followed.
c. If the Permittee had previously submitted emission estimates, the Permittee shall state that this report corrects or verifies the previous estimate. d. The specific operating parameter value, or range of values, that corresponds to compliance with the applicable emission limit.

e. The methods that will be used to determine continuous compliance. f. A description of the air pollution control technique for each emission point. g. A statement that the owner or operator has completed and has on file the operation and maintenance plan as required by the work practice standards of 40 eFR 63.342(f). h. If the Permittee is determining facility size based on actual cumulative rectifier capacity in accordance with 40 eFR 63.342(c) (2), records to support that the facility is small. i. A statement as to whether the source has complied with the provisions of 40 eFR 63, Subpart N. 

### ,J

### Page 5
6a. The Per.mittee shall prepare an ongoing compliance status report every year and retain the report on site, and make the report available to the Illinois EPA upon request, pursuant to 40 CFR 

### 63.347(h). However, if both of the following conditions are met, semiannual reports shall be prepared and submitted to the Illinois EPA: i. The total duration of excess emissions (as indicated by the monitoring data) is 1 percent or greater of the total operating time for the reporting period; and ii. The total duration of malfunctions of the add-on air pollution control device and monitoring equipment is 5 percent or greater of the total operating time. b. The ongoing compliance report shall contain the following: i. The company name and address of the source perfor.ming hard chrome plating operations. ii. 

### An identification of the operating parameter(s) that are monitored for compliance deter.mination. iii. The relevant emission limitation for the source, and the operating parameter value, or range of values, that correspond to compliance with this emission limitation as specified in the notification of compliance status. iv. The beginning and ending dates of the reporting period.
v. A description of the type of process performed in the source. vi. The total operating time of the source during the reporting period. vii. The actual cumUlative rectifier capacity expended during the reporting period, on a month-by-month basis, if the Per.mittee limits the maximum cumulative rectifier capacity less than 60 million amp-hr/yr. viii. A summary of operating parameter values, including the total duration of excess emissions during the reporting period as indicated by those values, the total duration of excess emissions expressed as a percent of the total source operating time during that reporting period, and a breakdown of the total duration of excess emissions during the reporting period into those that are due to process upsets, control equipment malfunctions, other known causes, and unknown causes. ix. A certification by a responsible official that the work practice standards are followed in accordance with the operation and maintenance plan for the source.
x. If the operation and maintenance plan was not followed, an explanation of the reasons for not following the provisions, an assessment of whether any excess emission and/or parameter

### Page 6 monitoring exceedances are believed to have occurred, and a copy of the report(s) documenting that the operation and maintenance plan was not followed. xi. A description of any changes in monitoring processes, or controls since the last reporting period. xii. The name, title, and signature of the responsible official who is certifying the accuracy of the report. xiii. The date of the ,report.
c. The Permittee shall report the results for each monitoring device. However, when one monitoring device is used as a backup for the primary monitoring device, the Permittee shall only report the results from the monitoring device used to meet the monitoring requirements. If both devices are used to meet these requirements, then the owner or operator shall report the results from each monitoring device for the relevant compliance period. 7. 

### Two (2) 

### copies of required reports and notifications concerning equipment operation or repairs, performance testing or a continuous monitoring system shall be sent to: Illinois EPA Bureau of Air Compliance section (#40) P.o. 

### Box 19276 

### Springfield, Illinois 62794-9276 

### and one (1) 

### copy shall be sent to the Illinois EPA's regional office at the following address unless otherwise indicated: Illinois EPA Division of Air Pollution Control Eisenhower Tower 1701 

### South First Avenue Maywood, Illinois 60153 

### It should be noted that this permit has been revised to no longer include operation of a natural gas-fired boiler, a polishing lathe, and a glass bead blasting operation controlled by a baghouse. Based on information submitted to the Illinois EPA at this time, operation of such equipment does not require a permit pursuant to 35 

### Ill. Adm. Code 201.146 

### (d), (aa), and (jj). If you have any questions on this, please call Jonathan Sperry at 217/782-2113. ,**.~**



### Donald E. Sutton, P.E. Manager, Permit Section Division of Air Pollution Control DES: JS:jar.::J;l
cc:

# Re~1 

# copy OriginalSigned by E 

# Oona'rt ltj

# ~nt.ton. 

# P.

.

### July 1, 1985 STATE OF ILLINOIS ENVIRONMENTAL PROTECTION AGENCY DIVISION OF AIR POLLUTION CONTROL 2200 CHURCHILL ROAD SPRINGFIELD. ILLINOIS 62706



### STANDARD CONDITIONS FOR OPERATING PERMITS

The Illinois Environmental Protection Act (Illinois Revised Statutes, Chapter 

### 111.1/2, Section 1039) grants the Environmental Protection Agency authority to impose conditions on permits which it issues. The following conditions are applicable unless superseded by special permit condition(s). 1. The issuance of this permit does not release the permittee from compliance with state and federal regulations

which arepartofthe IllinoisStateImplementationPlan,aswell aswithotherapplicable statutesandregulations of the United States or the State ofIllinois or with applicable local laws, ordinances andregulations. 2. The Agency has issued this permit based upon the information submitted by the permittee in the permit

.application. Any misinformation, false statement or mispresentation in the application shall be grounds for revocation under 35111. Adm. Code 201.207. 3. a. The permittee shall not authorize, cause, direct or allow any modification, as defined in 35 Ill. Adm. Code 201.102, of equipment, operations or practices which are reflected in the permit application as submitted unless a new application orrequest for revision ofthe existingpermitis filed with the Agency and unless a new permit or revision ofthe existing permit(s) is issued for such modification. b. This permit only covers emission sources and control equipment while physically present at the indicated plantlocation(s). Unless the permit specifically provides for equipmentrelocation, this permitisvoid for an item of equipment on the day it is removed from the permitted location(s) or if all equipment is removed, notwithstanding the expiration date specified on the permit. 4. The permittee shall allow any duly authorized agent of the Agency, upon the presentation of credentials, at reasonable times:

a. to enter the permittee'sproperty where actualorpotential effluent, emission or noise sourcesare located or where any activity is to be conducted pursuant to this permit, b. to have access to and to copy any records required to be kept under the terms and conditions ofthis permit,

c. to inspect, including during any hours ofoperation ofequipment constructed or operatedunder this permit, such equipmentand anyequipmentrequired

### to be kept, used, operated, calibratedandmaintainedunderthis permit,

. d. to obtain and remove samples ofany discharge or emission ofpollutants, and

e. to enter and utilize any photographic, recording, testing, monitoring or other equipment for the purpose of preserving, testing, monitoring or recording any activity, discharge or emission authorized by this permit. 5. The issuance of this permit:

a. shall not be considered as in any manner affecting the title of the premises upon which the permitted facilities are located, b. does notrelease thepermitteefrom any liability for damage to person or propertycausedbyorresultingfrom the construction, maintenance, or operation of the facilities,

lL**~3~·0224** Printed on Recycled Paper 090-006 APe 161 Fell. 11".-93

### C:llculation Sheet Facility: Ecolllony Plating, Inc

.

# yt Analysis Engineer: Jonathan Spe .., Review Engineer: Contact: Victor 1. Koemer (773-486·0960) Coullty: Cook, Region I (ozone 1I01l-attainlllent area) 

### imroduclioll Dale: 

### 3 / 31/ 98 Dale: ID: 031600CVM P.N

.:73031926 Date Received: 

### 11291 98

Application t o renew an operating pennit for chrome electroplating and to incorporate control equipment from construction pennit 97040058. 

### Flags Toxic Flag: toxic screening not required (JMS) No other nags (Legal, FOS, or NSPS/NESHAP)


### Anal ysi s The equipment at this facility includes 4 chrome electroplating tanks (#1, 4, 5, and 6). In a phone call on 

### 3/30 /

98, V. Koemer indicated that tank 112 has been completely shut down and tank #7 is being replaced (construction penuit 97040058). The chrome electroplaling tanks arc controlled by 3 composite mesh pad systems. From initial notificmion, dated 7(21/95, all tanks have stanup dates prior to 12/ 16/93 (i.e., existing tanks). TIle facility has tested the three chrome electroplating systems. Based on maximum rectifier capacit y, this is a large facility according to 40 CFR 63.341. However, the facility has submitted information from 1997 data to indicate that actual usage is less than 60 million amphr

/yr. Therefore, this is considered a small facility as long as records continue to show this (40 CFR 63.342(c)(2». The allowable emissions for each group oftanks with a common add-on air pollution control device is 0.03 mgldscm (13

. 11.1006 gr fdscf). Note that when the replacemcnt for tank #7 begins operation (with the appropriate notification and testing), the appropriate emissionlimitalion for tanks #5, 6, and 7 will be found using the procedure in 40 CFR 63.344(e)(4)

. operating hours = 24 · 6·52 = 7488 lIr/yr total gas now through controls = 16,000 cflll total reclifiercapacity (all 4 chrome plating tanks currently in usc) = 18,000 amps maximum potential rectifier capacity = 18,000 amps" 8400 hr!yr " 0.7 = 105

.84 million amp-hr!yr actual rectifier usage = IS.8 million amp-hr/yr (based on 1997 data) The calcul ations below for chromium emissions lise the following cOllversion faclor: 1 mg / dscm = 6.243· 10'! lb!dscf Tanks Tota l Amperage Flow Rate of Control efm 

### #1 3000 3,000 #4 

### 3,000 3,000 5 and 6 

### 12.000 10,000 Totals 

### 18,000 16,000 MACT Standard grldscm Ib/hr



### 0.03 3.37E-04 Actual Emissions grldscm IbIllf 

### 0

.0103 1

.16E-04 0.03 3.37E

-04 0.0137 1.S4E-04 0.03 1.12E

-03 0.0083 3.11 E-04 1.80E-03 S.81E-04

Other equipment at this facility includes shot blasting, polishing, and a boiler (2.9 mmBtu/hr). This equipment is now exempt from pennitting requirements

similar to APC·268 Sheet I of**~** Revised 1 / 98Calculation Sheet

- Economy Plating, Inc. ID 031600CVM App. No. 73031926 

### Rules • 40 CFR 63, SubpartN: NESHAP for Chrome Electroplating; this is a small, existing facility, soCr emissions are limited to 0.03 mgldscm (63.342(c)(I)(ii»; required to obtain a Title V permit (63.340(e», however, the USEPA has deferred for 5 years (up to December 1999)the requirement for a Title V permit forthis non-majorfacility; this facility apparently requested a compliance extension, but 

### itwasreceived too late according to 63.343(a)(6) • Section 201.146: blasting,polishing, and a boilerare exempt from state permittingrequirement


### Recommendation/Conclusion Grant NESHAP operatingpermit EIS coded 

### (3/30/98)

similarto APe-268 Revised )198 Sheet 2 of 

### '2:-

### Indexto Submission Items 1. APC Form 200 for exhaust blower# 1 2. APC Form 200 for exhaust blower # 

### 4 3. APCForm 200for exhaustblower

### # 5 

### & 6 4. APCForm260for exhaust blower

## # 1 5. APC Form 260 for exhaust blower

### # 4 6. APC Form 260 for exhaust blower# 5 

### & 6 7. APC Form 205 for plating tank

### # 1 8. APC Form 205 for plating tank# 4 9. APCForm 205 for plating tank# 5 10. APC Form 205 for plating tank# 6 11. 

## APc Form205 for polishing lathe 12. APC Form 205 for boiler 13. APC Form 205 for sandblaster 14. APCForm205 for sandblasterbag house. 15. APCForm 210 16. Final Report ofEmission Test. 17. TestProtocol. (prot-I) 18. Rawtest data for 3 tests of# 1 exhaust (test-I) 19. Traversepressure and angle calculations for # 1 system. (trav-I) 20. Rawtest datafor 3 tests of# 4 exhaust. (test-4) 21. Traverse pressure and angle calculations for # 4 system. (trav-4) 22. Raw test datafor 3 tests of# 5 & 6 exhaust. (test-5 & 6) 23. Traverse pressure and angle calculationsfor # 5 & 6 system. (trav-5) 24. Lab results from exhaust test for #1. (Lab- 1) 25. Labresults from exhaust test for

### # 4. (Lab-4) 26. Lab results from exhaust test for

### # 5 & 

### 6. (Lab-5 & 

### 6) 27. Copy ofCalibration ofgas meter and critical orifice use in tests. (Cert-l) 28. Diagram oftest ports for# 1. (port-I) 29. Diagramoftest ports for 

### # 4. (Port-4) 30. Diagramoftest ports for # 5 & 6. (Port-5 & 6) 31. Specifications for CompositeMesh Pad system on 

### # 5 & 

### 6. (Spec 5 & 

### 6) 32. Specifications for CompositeMesh Pad system with mist eliminator for# 

### 1. (Spec-I) 33. Specificationsfor CompositeMeshPad system with mist eliminator for # 4. (Spec-4) 34. Process diagram. (Process) 35. PlotDiagram. (plot) 36. 12 Monthrolling amphour report. (Roll-I)